ŞARA GROUP HOME PAGE ABOUT US ACTIVITY AREAS PRODUCTS CAREER CONTACT TR EN ETHICS AND COMPLIANCE PROCEDURE 1. AIM ŞA-RA Enerji İnşaat Tic. ve San. A.Ş. ("ŞA-RA” or the "Company") operates within the framework of this ŞA-RA Ethics and Compliance Procedure that was prepared by the Board of Directors and disclosed to the public through its website. ŞA-RA Ethics and Compliance Principles are a set of rules designed to improve the effectiveness of internal relations and relations between the Company and all employees with customers, suppliers and other stakeholders, improving service quality, effective use of resources and preventing unfair competition. The ultimate goal of the ŞA-RA Code Ethics and Compliance Principles is to write our code of conduct to create a common corporate culture on business ethics, and to increase the awareness of our employees and stakeholders as an institution responsible to the community. Accordingly, it is aimed to provide guidance to the employees of ŞA-RA and those acting on behalf of the institution to act in accordance with the laws and business ethics in the decisions they will make while carrying out their duties and the actions they will perform. 2. SCOPE The Ethics and Compliance Principles are integrated with the Company policies, values and principles and ŞA-RA together with its subsidiaries (“ŞA-RA Group”), employees, Executive Board members, suppliers and business partners, agents, contractors, those who work by proxy, and all third parties to be worked with are included. 3. RESPONSIBILITY The preparation and update of this present Procedure is under the responsibility of the Human Resource Management and Corporate Governance Committee, and it is approved by the Executive Board. 4. APPLICATION PROCEDURE 4.1. ETHICAL PRINCIPLES 4.1.1. Compliance with Legislation • ŞA-RA ensures the highest level of compliance with the legislation at first together with all national and international rules and internal regulations. • ŞA-RA ensures that all financial reports, financial statements and records to be prepared are kept in accordance with national and international accounting standards. • In relation to investors, stakeholders and all shareholders, it acts indiscriminately in accordance with all laws, regulations, rules, principles and internal regulations, international law rules and ethics. 4.1.2. Confidentiality of Information and Protection of Trade Secrets • The confidentiality of all commercial and personal information about our employees, suppliers, business partners and customers is essential. In the process of processing this private and confidential information as a matter of business and duty, the relevant laws, legislation and regulations on access to and use of this data are complied with and shared only with the relevant authorized persons. It is not disclosed to third parties unless its disclosure is mandatory in accordance with official authorities and legislation. • Information and documents provided by the company that may be accessed or learned, trade secrets, financial and other information not disclosed to the public, and confidential information in agreements with third parties are evaluated within the framework of confidentiality and protection of trade secrets. • The company takes care to protect the personal information of its employees and all stakeholders. When using any information technology resources and electronic communication tools takes the utmost care in privacy and data security matters, the information that is used to access the password, the user password and the confidentiality of your user codes act with the awareness that it is the responsibility of, and is not shared with third parties, including colleagues or administrators. • Personal information belonging to employees is confidential and cannot be disclosed to anyone other than the authorities. Employees receive their own personal information. The personnel who receives the personal information shall keep this information of their own and shall not disclose it to anyone after reading it. • Employees know and act in accordance with the degrees of confidentiality of the information they obtain with reference to their duty. If a hesitation arises in terms of the degree of confidentiality, the administrator's opinion is asked. This information cannot be changed, copied, destroyed. The necessary precautions are taken to keep the information carefully, to keep it safe and not to reveal it. Work desks are collected before the end of work and confidential information/documents, if any, are locked, keys are stored in safe places. All kinds of data, information and documents that may damage the activities and reputation of the ŞA-RA Group, make it difficult in terms of competition and violate the privacy of private information are not excluded from the company by means of e-mail and other communication tools. Sharing of documents, papers, reports or works that do not contain the phrase "Not confidential" with third parties is strictly prohibited. But there may be exceptions with the approval of the Chair of the Executive Board. Passwords and user codes are kept confidential and not disclosed to anyone except authorized users. All kinds of information can be taken to CD/USB only if the work is required and the written consent of the managers is obtained. Confidential information is not discussed in public places such as elevators, service cars and so on. • The information about the company and its customers cannot be disclosed to anyone after leaving ŞA-Ra and cannot be used against ŞA-RA. It is the duty of every employee to establish, protect and defend our Company's intellectual property rights on everything commercially important and to ensure that these rights are exercised responsibly. • In cade the employee leaves the Company, for the protection of all the documents, papers and confidential information which they know due to their position and non-use of them against the Company in the future are carefully considered and necessary measures are taken. • Employees take care not to use critical information belonging to ŞA-RA and Group companies when using and talking mobile devices in public and social areas. • Employees of the Company may from time to time have access to internal information defined under the capital market legislation. Employees who receive internal information have an obligation to keep such information confidential within the framework of the provisions of the employment contract and/or confidentiality agreement and other internal regulations and procedures signed by them. • Employees of the company cannot disclose or use the internal information they have learned during their work in the company unless they are authorized by the Company. Employees of the Company are informed of the obligations under the relevant legislation in relation to internal information and the sanctions related to the misuse and improper distribution of such information. • It is unacceptable for employees to abuse this information in the stock market or by any means. These obligations of employees continue after leaving their duties. No employee of the Company may trade shares belonging to the Company or its subsidiaries or affiliates on the basis of internal information. • All official statements are disclosed to investors, shareholders and the public in a complete, simultaneous and understandable manner, in line with the principle of equality, through the person and/or units of the Company's mandate and authorization. 4.1.3. Compliance with Corporate Governance Principles • ŞA-RA informs its employees about corporate governance principles, ensures their adoption within the company and the full compliance with these principles. • It ensures that any information it makes available to the public is understood, accurate, clear, timely and complete. 4.1.4. Employees • ŞA-RA supports the principles in the OECD Guidelines for Multinational Enterprises, and complies with the declarations of International Labour Organisation (ILO) on collective bargaining and right to association, ban on forced labour and child labour in addition to the declarations against discrimination. • ŞA-RA respects human rights, individual differences and personal characteristics of people and supports the Universal Declaration of Human Rights of the United Nations. It rejects the use of child labour which is contrary to ILO principles and does not work with any supplier or subcontractor who uses children as labour force in contradiction with ILO principles. • ŞA-RA attaches great importance to the creation of a safe, healthy and appropriate working environment free from any kind of verbal and physical harassment based on race, ethnicity, religion, physical or sexual characteristics, sexual preference or any other factor prohibited by law. • ŞA-RA acts in a way to all employees and job applicants who enters relationships with the organisation in terms of the race, religion, gender, sexual preference, age, nationality, origin, or marital status, pregnancy, disability, or regardless of their disability status, and provides equal opportunity for all honest and fair. • There can be no exclusion in recruitment to those who fail to complete the required exams and interviews successfully. • The behaviours which can be seen as the annoyance on the matters like age, language, race, health condition, gender and marital status; any act of sexual harassment arising out of words, physical contact or conduct shall be evaluated by the Disciplinary Committee. • Measures to prevent “Mobbing” practices, which are defined as intimidating employees through psychological violence, pressure, siege, harassment, and annoyance are developed and special attention is given to the protection of the personality of our employees and they are not allowed to be subjected to any kind of psychological pressure and harassment, to the violation of personality values, to emotional attacks and intimidation. • Employees may not work or provide counselling in any paid or unpaid work, depending on another employer and/or within another legal entity, even outside their working period, "without the written consent of the employer". • ŞA-RA employees may not engage in activities that require them to be considered as “merchants” or “traders” by direct and indirect means, cannot establish a company directly or indirectly and cannot be a partner, board member or director of established companies, cannot make business partnerships, cannot take part in companies with which they are competitors or business associates. They can be employed in charitable, non-profit organizations where they do not disrupt their duties within the Company. • Out-of-work social activities that will enrich the social lives of employees are supported. • If human rights are at risk in the regions or countries in which we operate, the public authorities are contacted with. • We consider essential the solidarity with employees and their families in exceptional circumstances such as natural disasters. • Employees can make speeches and write professional articles on topics that do not concern ŞA-Ra and do not contradict the policies. Even if the subject is not associated with ŞA-RA, the person as an employee should always refrain from conduct that may damage the reputation of the Company. In order to use the name ŞA-RA in these activities, written approval must be obtained from the chair of the Executive Board. • The rights of employees to organise and collective bargaining are respected. • Employees may not provide financial and moral assistance to political activities even if they have financial means in the name of ŞA-RA. They cannot actively operate in any political party during their tenure. Managers cannot ask their employees to do political work or become members of a party. • Employees may personally provide financial or moral assistance to third parties other than ŞA-RA, make donations, and take part in charity associations. • It pays attention to the employment of the appropriate number of employees for each job and pays attention to acting in the awareness of working hours. By considering the use of annual leave for every employee, it ensures the regular use of annual leaves. • It pays attention to the timely and complete fulfilment of the rights of employees that may arise due to legislation. • Enables employees to participate in decision-making process • Employees may give statements, interviews, seminar, conference, etc.to any broadcaster with the approval of the chair of the Executive Board on the conditions of not obstructing the flow of work and not violating the confidentiality principle. They may attend the places as speakers or instructors and donate the proceeds from the event to a foundation that the chair of the Board deems appropriate. They can only be given the prize, documents and others which are just a memory of the day and has symbolic value. • Employees are expected to communicate and cooperate with each other in accordance with mutual trust, respect and courtesy rules. • Employees, in company-owned work areas, while doing company work, during the use of company-owned vehicles and equipment, cannot use illegal pills, alcohol, drugs, etc. it is prohibited to use and/or be under the influence of substances harmful to human health. • Gambling, betting and chance games during work hours are strictly prohibited. It is not possible to work with individuals who have such habits at the level of addiction outside the workplace and working hours. • The company does not interfere with the personal information and private life of its employees. Personnel information is only used for the purposes of the Company by authorized persons within the specified authority in case of need. • Employees are obliged to correctly declare and update the information requested by the Company's Human Resources Department; in addition, they are obliged to inform their respective managers and Company Human Resources Manager if they have any investigations and/or criminal cases against them initiated by Public Prosecutors for any reason other than their duties or works in Group Companies. 4.1.5. Responsibilities towards the Shareholders • ŞA-RA makes its decisions based on known economic criteria and ensures the most efficient management of its resources and assets with an understanding of financial discipline and accountability. • Aiming to maximize share value, the company implements growth-oriented value-creating strategies while avoiding unnecessary and unmanageable risks. • We develop and implement an honest, transparent, sustainable reporting system that is compliant with legal regulations and rules on the basis of commercial and financial discipline. We regularly provide the flow of information to the necessary individuals, institutions and organizations. In our statements to the public and to our shareholders, we provide timely, accurate, and understandable information about our financial statements, strategies and investments within the scope stipulated by the legislation. • Manages its work in such a way as to distribute dividends to its stakeholders in accordance with the dividend policy. • No employee other than the person and/or departments assigned duties and authority can make an oral or written statement on behalf of the company. 4.1.6. Relationships with Customers/ Subcontractors, Suppliers and Other Companies and Persons with whom the Company has a Commercial Relationship • We take all the technical and administrative precautions necessary to ensure the appropriate level of security of the personal information of the customers, subcontractors, suppliers, business partners pursuant to the Personal Data Protection Law No.6698, against the unlawful processing of personal data and prevent unlawful access to personal data in order to ensure the safekeeping of personal data. • ŞA-RA is sensitive, honest and fair in relationships with the customers, suppliers and business partners, and treats the customers by producing quick and permanent solutions on the basis of mutual trust and performs the product/service agreements in compliance with the internal regulations together with international and local legislation. • As ŞA-RA group, we take care to make decisions in line with objective criteria in the selection of our suppliers and business partners that we prefer to work in cooperation for a long time. • In establishing and maintaining commercial relations, we base criteria such as benefit/cost, objective, transparent, equal, independent, consistent with our corporate values and considering the benefit of our third party stakeholders without having any relationship of interest and/or influence of the person. • In relationships with customers, even in favour of the customer, a transaction cannot be made without the customer's knowledge. Even if it is in favour of ŞA-RA, customer weaknesses cannot be exploited and profit motive cannot be made by providing the customer with incomplete or incorrect information. • It protects the rights of its customers, considers their objections and complaints, makes the necessary investigations and assessments and strives to resolve them immediately. In case a ŞA-RA employee cannot solve any problem within the area of duty, the supervisor is notified. • No private business relationship can be sustained with the Company's customers/ subcontractors, suppliers and other companies and persons with whom the Company has a commercial relationship, no money/goods can be borrowed for personal purposes and no money/goods can be lend to the customer/subcontractor/supplier and other companies and persons with whom the Company has a commercial relationship. The purchase and/or demand of personal goods or services without paying any price from the customer/subcontractor/supplier and other companies and persons with whom the Company has a commercial relationship is considered to be a personal benefit and requires the penalty of termination. • We provide ŞA-RA Ethics and Compliance Principles booklet with our suppliers, subcontractors and business partners. • We expect our suppliers, subcontractors and business partners to comply with the ŞA-RA Ethics and Compliance Principles and Working Principles, share the same values and act within this framework. • Our suppliers, subcontractors and business partners are required to carry out their activities in accordance with laws and regulations related to ethical principles, to observe the rights of their employees and certain standards like the environmental protection; we oblige them to comply with the standards. 4.1.7. Relations with Competitors • As ŞA-RA and Group Companies, we act pursuant to the Law on Protection of Competition and all relevant legislation; we act meticulously on the freedom of competition and the development of the sector, the observance of common interests and the continuity of trust in the sector. It respects the conditions of fair competition in our relations with competing companies. • Violation of competition rules can result in high amount financial sanction and/or possible imprisonment, both individually and institutionally. All ŞA-RA Group employees comply with all applicable laws, regulations, statutory decrees and orders relating to the protection of competition. • ŞA-RA and Group Companies strictly refrain from agreements, behaviours and concerted actions with competitors or other third parties or entities which are intended directly and/or indirectly to hinder or limit competition, or which may have or may have result with such effect. • In cases where a particular market is dominated alone or in conjunction with other undertakings, such dominant position is not misused. • R Illegal and unethical means are not used when accessing information about our competitors. It uses only publicly owned information of competing companies and does not use information about competing companies whose source is not clear. 4.1.7.1. Commercial Associations Meetings held by commercial associations and other similar organizations are also places where competing firms come together and discuss various common concerns and interests that have the potential to go beyond the limits prescribed in competition laws. Therefore, caution should be exercised in meetings, if conversations are shifted in any way to attempts to restrict competition, talk about it is refused and the meeting is abandoned. 4.1.7.2. Commercial Intelligence When commercial information about other companies is accessed in any way, such information is accepted after it is concluded that it is not a moral and legal objection to receiving and using such information and that it is not a violation of any person's privacy obligations. In no event should any moral or illegal means be used to obtain such information, such as false or deceptive statements, deception, theft, espionage or bribery, or third parties be asked to do so. 4.1.8. Public Offices and Organisations • We act in line with the principle of equality in relations with public institutions and organizations. In carrying out our activities, we act on the principle of keeping equal distance from the public institutions and organizations, non-governmental organizations and political parties in question. Law and regulatory requirements are complied with; no interest relationship with public officials, political persons and representatives with or without material value shall be entered into. • It takes care to share information that needs to be disclosed to the public accurately, consistently and in a timely manner, and is sensitive about protecting internal information that should not be shared with the public. • Our employees who participate in bids, tender preparations or contract negotiations are held responsible for the accuracy and truth of all statements, correspondence and statements they give to the parties concerned. 4.1.9. Media / Social Media / Advertisement • Regular, open and transparent communication is maintained with the media. • The difference between media institutions is not observed, all of them are kept at equal distance. • Statements made to the media do not include information that would mislead the public. We do not make public statements as employees or managers except as spokespersons of the organisation. We do not use statements that will damage the reputation of the Company, do not include statements that are incompatible with the corporate culture, statements that contain discrimination in any way, political, hateful and insulting discourses. • Our employees do not share on their social media accounts the kind that would flatter the offender and/or the offender. They are expected to make shares that are worthy of the corporate reputation of ŞA-RA and Group companies in all digital media, especially social media. • As ŞA-RA group, no misleading or deceptive advertising is made, and no rhetoric is made that will damage the reputation of our competitors or the companies we are competing with. Our advertisements do not incite discrimination and violence against the public, and not violate the general code of ethics. We also ensure that advertising and/or sales materials are not printed and distributed without the approval of the necessary units and managers. • We respond to e-mail or sector-related questions and information requests from the media about ŞA-RA and the Group in writing under the coordination of the authorized corporate communication departments. 4.1.10. Use of Assets, Resources and Time in Enterprises 4.1.10.1. Use of Assets and Resources: • It is a general rule to use of assets and resources belonging to the ŞA-RA Group for the benefit of the company and to avoid to use for the benefit of individuals and third parties. Material belonging to the Company (cash and cash equivalents, stock, company vehicle, machinery and equipment, electronic devices, etc.) and intangible (information and Information systems, brand, reputation, intellectual property rights, trade secrets, etc.) assets and resources are used only within the principles and procedures permitted by the management or to carry out the business of the Company. • The company's assets, facilities and labour may not be used outside the company under any name, title or benefit without the benefit of the company. The principle of "saving in all matters" is applied by all personnel and in a way that is an example to the superior subordinate. • Our employees and stakeholders have the responsibility to use the assets and resources of ŞA-RA and ŞA-RA Group Companies efficiently, as well as to take all necessary measures to protect the tangible and intangible assets of the company. The employees refrain from behaviours and acts which can result with the damage (possible loss, damage, misuse, abuse, theft and sabotage of assets and resources, etc.) to such responsibility and act within the principle of “saving in all matters” while carrying out their duties. 4.1.10.2. Efficient and Productive Use of Working Hours • Working hours are created by taking into account the balance of work and private life. It is essential that our employees spend their working hours in an efficient and productive manner, conscious of their duties and responsibilities. • During business hours, employees do not engage in activities that are not related to their duties and responsibilities. It avoids all attitudes and behaviours, including gossip, that will negatively affect the workflow, disrupt the working order. • They use time well, they do not spend time on private business during business hours. Managers can't assign the employees for their personal business. • It is essential that no visitors are allowed for personal purposes during working hours. Company employees are required to complete interviews in connection with the subject of the visit and in a reasonable time so as not to interfere with the workflow. 4.1.11. Engaging in Activities Creating Conflicts of Interest • Conflict of interest refers to a situation in which employees have personal interests that affect or may lead to a perception that they are affecting their duties impartially and objectively. It covers all benefits to themselves, their relatives and relatives, or the person or entity in which they are related, and any other financial or intangible obligations related to them. A material conflict of interest involves a real or potential financial gain. However, this material gain is not required to be cash. Earnings, such as gifts and catering, also fall within this scope. • In the case of intangible conflicts of interest, there is no financial gain, but there is a personal interest. The use of influence trading, reputation and liaison can also be evaluated in this context. • While the possibility of the employee's behaviour being affected is sufficient for a conflict of interest, another criterion for determining a conflict of interest is that a third party looking outside thinks that the objectivity of the employee may be affected in the face of such situation. 4.1.11.1 Relations with Relatives • If the candidate to be recruited has a relationship with the personnel working in the workplace including second degree blood and marriage relations, it is not accepted to work in the same departments or to be in a subordinate relationship. However, if the employer's interests are required to work in the same departments or to be in a subordinate relationship, the situation is subject to the approval of the chair of the Executive Board. • Employees may enter into employment relations with their spouses, relatives and friends only with the knowledge of the chair of the Executive Board. 4.1.11.2. Receiving and Giving Gifts, Representing and Hosting • Employees are transparent during their relationships with customers/subcontractors/suppliers and during and after the determination of the firms and individuals with who ŞA-RA will have any relation, they cannot imply or ask for any gift that may have an impact on their decision making process; also they cannot accept any gift, money, cheque, property, free vocation, special discounts which may impose to ŞA-RA any obligation. • We act in accordance with the law and related regulations in the event that violations are detected and proven that will affect the main activities and financial statements of the ŞA-RA Group Companies, cause violations of the relevant laws, damage the corporate image and/or benefit the employee due to his / her position and position in the ŞA-RA group. • As SHA-RA Group employees, we act with the awareness that it is essential that we do not demand, offer to third parties, or accept any discounts or benefits that may be perceived as inappropriate from ŞA-RA Group Companies or the real or legal persons with whom we have a corporate business relationship. On the other hand, we do not have any borrowing-lending relations with any third party (suppliers and business partners, dealers and authorised dealers and authorised services) having direct or indirect relations with our duties. • We reserve a representation expense allowance for the cost of hosting customers and business meetings. We want representation costs to be used only in areas where they are relevant. • It is essential that the expenditures made are documented by invoice and no invoice can be obtained from another place for the expenditure that is not invoiced originally. If necessary, we ask that the issuance of expense receipt in accordance with the law. Expenses that are not accepted by law (KKE) are kept in expense accounts that are not accepted by law (KKE) and are recorded in accounts receivable at the respective companies. • Business-related hospitality activities are carefully supervised and approved by the Company's senior management with the help of corporate standards and relevant internal regulations. Other than that, the cost of hospitality is unacceptable. 4.1.11.3. Representation and Participation in Invitations of Organisations Organizations open to general participation (conferences, receptions, promotional activities, seminars, etc.) organized by associations and non-governmental organizations with institutional membership, can be attended by the employees meeting the corporate membership conditions with the approval of the higher manager. No written consent is required for this. 4.1.12. Prevention of Money Laundering, Fight against Corruption and Bribery • The money laundering is transactions and activities in which individuals hide, conceal or display the nature, origin, location, status, movement and belonging of cash and similar assets acquired from crime in order to conceal their crimes or to give legal appearance to the proceeds of crime. • As ŞA-RA, we adopt the fight against money laundering, terrorism financing, corruption and similar crimes as an important principle within the framework of the provisions of national and international legislation. We strictly demand our employees to comply with all applicable laws and regulations regarding anti-money laundering and anti-corruption. • ŞA-RA has the principle that is against the bribery and corruption with reference to the business ethics and Turkish Penal Code as a criminal act because it is legally banned; ŞA-RA in all countries where the group companies operate and where anti-corruption laws and regulations, the norms of universal law, ethical and professional principles, particularly the principles of corporate governance are in force, ensures the compliance with other internal regulations and other statutory regulations. • Any corruption and bribery that damages the reputation of ŞA-RA and the employees is also treated with diligence and sensitivity and our employees, our suppliers and business partners, our customers and consumers, competitors and other third-party stakeholders, to demand the company to take advantage of exclusive benefits and conditions for personal gain, to request a special concession or discount that's available to everyone except to ask for a personal loan are not allowed. ŞA-RA employees are prohibited from receiving and giving cash, money, commissions, profits and contributions, or any form of bribery under any name. There will be no retaliation, no punishment for the employee who refuses to pay bribes. • It is essential that employees and all third parties acting on behalf of ŞA-RA indicate due care and diligence; that they do not make unfair profits from persons and organizations for any purpose whatsoever, do not offer, receive or give bribes or commissions, and that they prevent such actions to the extent that they have information. When such an offer is encountered and there is any observation or doubt about it, the situation should be reported to the connected manager and/or to the Ethical Principles notification line. 4.1.13. Social / Societal Responsibility / Environment and Health / Work Safety 4.1.13.1 Social Responsibility • As ŞA-RA, we act with the understanding of creating common value in our social investments. • In accordance with the social responsibility approach, our employees are supported to participate in volunteering and assistance projects with the understanding of contributing to the development of the society and creating value. • With reference to the work ethic and the sense of social responsibility, it acts in a manner sensitive to the problems of society and our community, contribute to the development of projects that takes place to provide support, fundraising, cultural, artistic, scientific and sporting activities contributes to supporting social life. • As an institution, care is taken not to provide our social support to projects, institutions and organizations that would damage the reputation of ŞA-RA, to political activities and to individuals and organizations associated with these activities, to private accounts and to profit-oriented organizations. 4.1.13.2. Environment and Health • We carry out all our activities and investments in harmony with the environment and evaluate the environment in terms of sustainable use of natural resources and keeping the negative impacts that may occur in nature to a minimum level. • Protecting nature in line with environmental legislation is part of our responsibility to future generations in the long term. We develop innovative solutions to continuously improve environmental performance, use natural resources, especially soil and water, prudently and efficiently, minimize carbon emissions and waste, and improve recycling. • We develop methods of protecting natural resources such as energy and water and carry out studies for efficient use of energy and materials. • We define the risks in relation with the environment and change in climate and take precautions to reduce. • We give environmental training to employees and subcontractors to raise their awareness. • In our work, we comply with all occupational safety and health laws and standards. • We apply the “Risk Management” principles to form a safe and healthy working environment. • We ensure and enforce the use of adequate protective equipment and safety precautions. • We note that implementing the Company policies and regulations related to health and safety at work is an important responsibility for all our employees. 4.1.13.3. Work Health and Safety • Managers and employees care about safety in the workplace. • Employees fulfil their duty by being aware that they have a responsibility to ensure the safety of the company and all employees. • The information in the trainings and announcements given by the Human Resources Department is provided to be known by everyone and the published instructions are followed in case of fire and similar natural disasters. • The health and safety of our employees, customers, consumers and everyone in business relations with our company is the priority in all our activities. Detailed records of Environmental, Health, Occupational Safety Training and violations and accidents are kept. 4.1.14. Marketing and Advertorial Activities 4.1.14.1. Explanation of Product Details • ŞA-RA aims to provide continuous and complete information on the types of use, safety, unexpected effects and side effects of the products, and, if necessary, their operational characteristics and conditions. This information is provided to the addressees of the subject with short product information/instructions for use and other promotional methods. 4.1.14.2. Product and Service Quality • We act in accordance with the laws and regulations of the countries in which we operate, and contribute to the formation of the relevant principles, standards and principles of the product and market in order to ensure product quality and consumer well-being. • We carry out our activities in accordance with the national quality standards such as Turkish Standards Institute (TSE) and international standards like International Organization for Standardization (ISO), and we retain the quality certificates we have with all our employees. Within the framework of our ethical approach, as a leading company, we use technologies that will contribute to the lives of individuals and support their better lives, and we use technologies that will support their benefit lives with these technologies, and we produce products that benefit them. • We offer our customers high quality products that they can easily reach with the best service. 5. Application Principles, Compliance and Violations We carry out all our activities and operations at home and abroad within the framework of laws and international law. We attach importance to accurate and timely communication in our relations with regulatory agencies and organizations. We conduct our business within the framework of laws, regulations and professional standards as well as the ethical principles of ŞA-RA. Employees of ŞA-RA Group Companies are obliged to comply with the ethical principles in carrying out their duties. In addition to the administrative and criminal sanctions prescribed by the relevant legislation, the contravention of the issues contained in these ethical principles also leads to internal sanctions. In addition, the status and performance of employees are evaluated in terms of compliance with the ethical principles. 5.1. Ethics and Compliance Committee It is the responsibility of the Human Resources Department of the Company by having the recommendations of the “ŞA-RA Enerji A.Ş. Ethics and Compliance Committee” (“Ethical Committee”) to perform any work to be deemed necessary for the aim of internalisation, improvement and sustaining the ethical culture; in addition to create, update, publish, ensure the applicability of ethical principles, coordinate training programs for those employed and employees in this regard, or cooperate with specialized organizations on these issues. 5.2. Briefing Our employees at all levels working within the ŞA-RA Group are informed about the Ethical Principles and the responsibilities related to these principles as an integral part of the business contracts and a commitment to read and understand the principles is kept in the personal file by the Human Resources Department. Ethical principles are also included in the corporate internet address of the Company. 5.3. Ethical Code of Conducts Application Principles The ethical principles define the processes to be followed in the event of the occurrence of attitudes and behaviours that violate or in contradiction with the rules required for a harmonious and efficient working environment within the ŞA-RA Group and determine the sanctions to be applied at the end of the process. Employees are expected to act with personal conscience and common sense in addition to compliance with laws and regulations, these business ethical principles, obligations arising from other company procedures, policies and regulations. 5.3.1. Obligation of Notifying the Violations and Ethical Principles Notification Line It is absolutely forbidden for the employees to have directly or indirectly personal gain from all the processes and contracts which the Company is a party for sale or purchase, or use of the authority and responsibility of employees in their own interests, or the care that is expected from them as a result of use outside of the company and the harm to customers or even the attempt to such action. Employees must adopt the Ethical Principles and act within the framework of these principles when performing their daily works/operations. Employees may consult their senior managers or human resources managers when they need them on ethical principles. In addition, all employees who wish to communicate or consult in the event of any doubt regarding the content of the Ethical Principles and/or witness any conduct or practice contrary to the code; • Via e-mail to Ethical Principles Notification Line (etik@sara.com.tr) • To Ethical Principles Notification Line between 08:30 and 18:00 by dialling (0 505 143 89 20). These notification lines are intended only for notification of matters deemed not to be in compliance with the ethical principles, such as customer or consumer complaints, suggestions, objections, etc. requests are not considered within the scope of Ethical Principles Notification Line activities. It is essential that the identity of the employees / persons reporting the violation be kept confidential within the framework of law and administrative requirements. The rights of employees/ persons reporting violations are protected. In case of false statements that are deemed to be fraudulent, they are removed from the transaction and the employees who do so consciously are sanctioned within the framework of the Disciplinary Directive. All employees and managers who approve, direct or have knowledge of the conduct contrary to the ethical principles and who do not make the necessary notification in the appropriate manner, condone them and give permission are also processed within the framework of the disciplinary regulation. 5.3.2. Authority to Inspect and Search Violation Notifications and Reporting Notices to the Ethical Principles Notification Line are made by e-mail, an ethical telephone line or a sealed envelope in writing. While the inclusion of the name is preferred during an infringement notice, but anonymous notices are also taken into account. All notices are kept confidential. ŞA-RA is committed to protect the rights of its employees who report for ethical principles. No employee shall be allowed to retaliate because of the notification, and necessary actions shall be taken against those who attempt to retaliate. The complaints, notices and allegations that come to the Ethical Principles Notification Line are prioritized by the ŞA-RA, listed and reported in writing by human resources to the Executive Board member responsible for the Ethical Principles and, where necessary, to the rating of the violation by the board member, to the relevant support unit (Law, Internal Audit, HR, etc.) is also reported to the Ethics Committee by taking the opinion. The Ethics Committee is authorized and responsible for the evaluation and resolution of the complaints, claims and allegations received. In this context, the knowledge of the violation related to ethical principles is assessed by "ŞA-RA Enerji A.Ş. Ethics and Compliance Committee”. In this context, the necessary investigation and research is carried out on the conduct and practices contrary to the ethical principles, ex officio or on the applications to be made. If it is determined that there is a transaction or action contrary to the ethical principles, the report on this situation or the result of the investigation that the conduct contrary to the ethical principles cannot be determined shall be forwarded to the chair of the Executive Board of ŞA-RA. Appropriate actions and measures are taken in line with the decisions to be taken. 5.3.3. Discipline Application For those who violate ethical principles, the provisions of the disciplinary regulations are applied. Failure to comply with laws and regulations, ethical principles and other ŞA-RA group policies, procedures and regulations can lead to criminal consequences up to termination of the employment contract. 6. TRAINING AND REGULAR ASSESSMENT ŞA-RA ethical and compliance principles and working principles are notified to the personnel and necessary training is given. Violations are assessed among very important risk factors, and in its application the target is zero tolerance. Information about the training is recorded. The application of this procedure is followed by the Corporate Governance Committee, regularly reviewed and submitted to the Executive Board annually, with the necessary updates to the Ethical Principles to be determined. ŞA-RA Group Merkez Ümit Mahallesi Meksika Caddesi 2479. Sokak No:2 Nokta Ankara, 06810 Çankaya / Ankara / Türkiye + 90 312 285 24 24 + 90 312 285 24 28 info@sara.com.tr