Code of Business EthicsHR ApplicationsJob Applications
Code of Business Ethics




Integrity and honesty are our primary principles in all our business processes and relationships. We act with integrity and honesty in our relations with all our stakeholders.


B.Conflict of Interest

A conflict of interest is a situation that affects the impartiality of employees and indicates the potential of employees to obtain any kind of benefit and any personal interest.


As Yünsa employees, we aim to avoid conflict of interest. We do not take advantage of our current position to gain personal benefits from persons and organizations with whom we have business relations personally, through our families or relatives. We do not engage in business activities outside our company based on an additional financial interest. We refrain from using the name and power of our company and our corporate identity for personal benefit.


In the event of a potential conflict of interest, when we believe that the interests of the parties involved can be safely protected through legal and ethical means, we apply these methods. When in doubt, we consult our Manager, Human Resources and Corporate Development Manager, Company’s Attorney, Code of Ethics Consultant or Ethics Committee.


ØConflict of Interest Policy

It is essential that the employees of Yünsa Yünlü Sanayi ve Ticaret A.Ş. avoid situations that may create conflict of interest. It is one of the most important responsibilities of all employees not to use company resources, name, identity and power for personal benefit, and to avoid situations that will negatively affect the name and image of the company. The following codes of practice sets out the conflicts of interest that Company employees may encounter during the performance of their duties or in their private lives due to their business relationships and the principles to be applied in these situations.


Codes of Practice

All the employees are required to fully comply with the situations identified below as activities that may create conflicts of interest and the principles stated below. The Company carries out the necessary work to encourage its employees to comply with these principles.


i.Engaging in Activities that may Create Conflicts of Interest

  1. Employees shall not enter into any business relationship with their family members, friends or other third parties that provide reciprocal or unrequited benefits under any circumstances. In the same vein, Company employees shall be cautious about conflicts of interest that may arise due to the employment of their close family members in the Company's competitors. For example, an employee with procurement power shall avoid doing business with a supplier where one of his/her family members work. Exceptional cases are subject to the opinion of the Ethics Committee and the approval of the General Manager.
  2. At Yünsa, it is essential that employees who are spouses and third degree relatives (including in-laws) do not have reporting ties with each other in the same organization or take part in decision-making mechanisms together.
  3. It is essential that employees of YÜNSA are not in a partnership, board membership, consultancy or employee relationship with organizations that have a competitor, supplier or customer relationship with Yünsa or are in an effort to do business with Yünsa.



  1. Employees may not obtain any commercial benefit, including the purchase and sale of shares on the stock exchange, by leaking any information of the Company, nor may they conduce others to obtain such benefit.
  2. It is essential that the employees of the Company do not work for another person and/or organization under any name whatsoever within or outside working hours in return for a wage or similar benefit, and do not engage in activities that require them to be considered as “merchants” or “tradesmen” directly or indirectly. However, it is possible for employees to work for another person (family member, friend, other third parties) and/or organization for a wage or similar benefit outside of working hours subject to the written approval of the Management as stated below, provided that;
    • It does not to create any conflict of interest with their duties in the Company and Company’s practices,
    • It does not create incompatibility with other business ethics rules and policies that support these rules,
    • It does not adversely affect the continuation of their duties in the Company:
      • Opinion of their line managers
      • Opinion of the Ethics Committee/Ethics Consultant
      • Opinion of the Human Resources and Corporate Development Manager
      • Opinion of the General Manager
  3. Company employees may not serve as board members or auditors in other companies without the approval of the Company's Board of Directors, and may not take office in competitors or companies with which the Company has business relations. They may work in non-profit organizations and universities for social responsibility and charity purposes with the written approval of the management, provided that it does not interfere with their duties within the Company.
  4. Managers who are in a position to make hiring decisions may not hire their spouses, close relatives and relatives of these persons.
  5. Employees may make speeches and write professional articles on topics that are not related to the Company and its activities and that do not contradict its policies. Approval of the General Manager is required to use the Company’s name in these activities.
  6. Managers may not ask their employees to do political works or become a member of a party. Employees may, individually and voluntarily, actively serve in any political party. In the event that employees take part in any political party, it is essential that they pay attention to the following issues;
    • Employees' involvement in any political activity should not create a conflict of interest between their duties in the Company and the Company's practices and approaches.
    • Employees may not engage in any political activity during working hours and may not occupy their colleagues' time for such activities.
    • Employees may not use the Company name, their positions and titles in the Company and resources of the Company during their political activities.
  7. Employees may personally provide material or moral aids and/or donations to third parties outside the Company, and may take part in charity associations. Employees take care not to become a member of any club, association or cooperative by using the Company’s name and their positions.



It is unacceptable for employees to harm the Company by using their authorities for their own and/or their relatives' benefit and without the due diligence expected from them.

Employees may not directly or indirectly obtain personal benefits from the Company's procurement and sales activities and all transactions and contracts to which the Company is a party.

Employees may not engage in acts and behaviors contrary to morality, the law and Company discipline.



iii.Use of Resources

The interests of the Company are taken into account during the use of resources on behalf of the Company. Company assets, facilities and employees may not be used outside the Company under any name and on behalf of and for the benefit of anyone, without the Company's interest. The principle of “economy in everything” is practiced by all employees.

The proper use of resources for the benefit of the Company also requires the proper use of time. Company’s employees make good use of time during working hours and do not spare time for their personal affairs during working hours. Managers cannot assign employees for their personal affairs.

No private visitors are allowed during working hours. Employees are required to complete interviews for mandatory visitors within a reasonable time in connection with the subject of the visit and in a manner that does not interfere with the work flow.


iv.Relations with Other Persons and/or Organizations with whom the Company has Commercial Relations

No private business relationship may be entered into with the Company's customers, subcontractors or suppliers and other persons and/or organizations with whom the Company has commercial relations, no money and/or goods/services may be borrowed for personal purposes, and no money and/or goods/services may be lent to other persons and/or organizations with whom the Company has commercial relations.


In relations with customers, even if it is in favor of the customer, a transaction cannot be made without the customer's knowledge, customer’s weaknesses cannot be exploited and profit cannot be pursued by providing incomplete or incorrect information to the customer.


Company employees may not request gifts from other persons and/or organizations with which the Company has commercial relations or imply the same; and they may not accept any gifts, money, checks, properties, free holidays, special discounts, etc. that would put the Company under obligation. Personal aids and donations cannot be accepted from any person or organization that has a business relationship with the Company. Gift Acceptance and Giving Policy is applied in this regard.


v.Relations with the Media

In relations with the media, Company’s communication principles, procedures and instructions are followed.


Giving a statement to any media organization, conducting interviews, attending seminars, conferences, etc. as a speaker is subject to the approval of the senior management of the Company. No information or disclosure about the Company may be made to any media organization without the knowledge and approval of the Company’s management. No personal gain can be obtained in any way from these activities.


vi.Representing the Company

Any remuneration that may be obtained as a result of the duties performed in all kinds of associations, employers' unions and similar non-governmental organizations as a representative of the Company shall be donated to the relevant institution or to the channels to be indicated by the relevant institution.


Payments that may be made by third parties to the Company’s employee as a seminar speaker fee or in return for a similar service shall be similarly donated to the relevant institution or to the channels to be indicated by the institution. In addition to money, these people may receive gifts such as awards, plaques, etc., which are given to commemorate the day and have symbolic values.



vii.Accepting and Giving Gifts

  • Gift Acceptance and Giving Policy

It is essential that gifts or benefits that may affect the impartiality, decisions and behaviors of Yünsa Yünlü Sanayi ve Ticaret A.Ş. and its employees should not be accepted, and gifts and benefits should not be provided to third parties and organizations that may create such effects. The codes of practice defined below regulates the gift exchanges of Company employees with third parties and organizations with whom they have business relations and sets out the principles to be applied in this regard.


Codes of Practice

  1. Company employees may not accept any benefit or gift, with or without economic value, that affects or is likely to affect their impartiality, performance or decision-making while performing their duties.
  2. Company employees may receive and/or give the gifts outlined in Article 3 or agree to be subjected to a special treatment, provided that;
    • They are aligned with the organization's business objectives,
    • They are in accordance with applicable legislation and
    • Public disclosure of the gift
    • will not put the Company in a difficult situation.
  3. Provided that it complies with the conditions set out in Article 2 above;
    • In seminars and similar organizations attended on behalf of the Company, gifts such as awards, plates, etc. with symbolic value may be received in addition to money as a commemoration of the day.
  4. Gifts, benefits, vacations, discounts, etc. other than the aforementioned situations and money may be accepted without the need for approval if the total value of the gifts received is less than 300 TL for each calendar year and the person/institution giving the gift are separate, provided that they comply with the conditions listed in Article 2.
  5. Gifts or benefits that are indirectly or explicitly linked to a quid pro quo cannot be received.
  6. Receiving, giving or offering bribes and/or kickbacks is not acceptable under any circumstances.
  7. Company employees may not accept money from subcontractors, suppliers, consultants, competitors and/or customers for free or as a loan, and may not have their travel expenses, event expenses and similar payments reimbursed.
  8. The gifts and promotional materials to be given by the Company to customers, dealers and other third parties with whom the Company has business relations shall be approved by the Company's senior management. No further authorization is required for the distribution of approved gifts and promotional materials.
  9. Provided that it complies with the conditions listed in Article 2 above, the Company may accept appropriate products and services as gifts and, with the knowledge and approval of the Company's senior management, products or services that are appropriate to the culture and ethical values of the recipient may be given as gifts.
  10. In exceptional cases where local cultural values require reciprocal gifts above the values set in the Company policy, these gifts can only be accepted on behalf of the Company and with the approval of the Company's senior management. In any case, the gift exchange should be made in accordance with local culture.



Confidential information includes information that may create competitive disadvantages for our Company, trade secrets, financial and other information that has not yet been disclosed to the public, information on personnel rights, personal data of our employees, customers and stakeholders, and information that we are obliged to protect within the framework of “confidentiality agreements” made with third parties.




As Yünsa employees, we take care to protect the confidentiality and private information of our customers, employees and other relevant persons and organizations we work with. We protect confidential information regarding the activities of our Company, use this information only for the purposes of our Company, and share this information with the relevant persons only within the scope of the specified authorizations.


It is absolutely unacceptable to obtain any commercial benefit, including the purchase and sale of shares on stock exchanges, by leaking any confidential information of the Company. When we leave our company, we do not take out confidential information and documents and projects, regulations, etc. that we have due to our duties.

ØPolicy on the Protection of Confidential Information

Information is one of the most important assets that the Company will use to realize its vision. Accordingly, it is the common responsibility of all our companies and employees to use information effectively, to share it correctly and to ensure the confidentiality, integrity and accessibility of information in this process. The following codes of practice define confidential information for the Company and set out the principles that employees must comply with regarding confidential information.


Codes of Practice

Confidential information includes, but is not limited to, information that may create competitive disadvantages for our Company, trade secrets, financial and other information that has not yet been disclosed to the public, information on employee rights, personal data of our employees, customers and stakeholders, and information that we are obliged to protect within the framework of “confidentiality agreements” made with third parties.


The principles to be followed regarding confidential information are given below:

  1. This information cannot be disclosed to third parties unless disclosure is mandatory in accordance with the Public Authorities and Legislation.
  2. This information cannot be changed, copied or destroyed. Necessary measures shall be taken to ensure that information is kept and stored carefully and not disclosed. Changes to the information are recorded together with its history.
  3. Confidential data, any disclosed information, documents, inventions, works, methods, progress and patents, copyrights, trademarks, papers, data, drawings, technical drawings, ideas, specifications, diagrams, detailed designs, models, samples, flow diagrams, computer programs, disks, any data-carrying equipment, technology, know-how, financial and commercial information, marketing policies, price policies, suppliers, customers, dealers and experience, all other kinds of innovations even if they cannot be subject to legal protection as trade secrets, and all commercial, financial, technical information that the parties will learn in writing or verbally during the commercial and/or contractual relationship between them, regardless of its subject matter, shall be deemed as Confidential Information unless otherwise stated by Yünsa in writing and in a clear manner. For confidential information that needs to be taken out of the organization, the approval of the person responsible for the information, Information Technologies Manager, the internal audit manager (President) and the senior management (Director /General Manager) shall be obtained.
  4. Passwords, user codes and similar identifying information used to access Company details shall be kept confidential and not disclosed to anyone other than authorized users.
  5. Company’s confidential information cannot be spoken in dining halls, cafeterias, elevators, service cars and similar public places in internal or external environments that may adversely affect the image and reputation of Yünsa, and cannot be shared on social media accounts and mobile phone applications. It can only be shared by the authorized



employees in the social media accounts and mobile applications of the company, within the scope and time allowed by the Company Management.

  1. Confidential information is classified according to their degree of secrecy and this is clearly indicated in the content of the information. Company employees know the confidentiality degree of the information they obtained as part of their duties and act in accordance with this confidentiality. In case of any hesitation in terms of the degree of confidentiality, the higher level of confidentiality shall be followed and the opinion of the relevant manager shall be sought when necessary.
  2. In the event that information is shared with third parties and/or organizations for the benefit of the Company, a confidentiality agreement is first signed for information sharing or a written Yünsa Confidentiality Agreement is taken from the other party in order to ensure that these persons and organizations understand their responsibilities regarding the security and protection of the shared information. The company attorney’s support should be obtained in these practices.
  3. No unfounded statements may be made about the Company, its executives and employees, and no positive or negative information may be shared.
  4. Wages, fringe benefits and similar personal information of employees, which reflect the Company policy and are personalized, are confidential and cannot be disclosed to anyone other than authorized persons. Employees’ information is sent on a private basis. The employees may not disclose this information to others either inside or outside the company or force other employees to disclose the information.
  5. The legislation on the Protection of Personal Data is followed.
  6. Ethical obligations above regarding confidentiality continue for the period after leaving the company for employees who leave the job for any reason.


D.Our Responsibilities

We take care to maintain our reputation in the eyes of our business partners, customers and other stakeholders at the highest level. We show the necessary dedication to fulfill our obligations within the framework of company policies, professional standards, our commitments and ethical rules.

We express only the views of our company, not our own views, in public and in areas where the audience thinks that we are speaking on behalf of our company.

i.Our Legal Responsibilities

We conduct our current activities and operations at home and abroad within the frame of the laws of the Republic of Türkiye and international law, and provide accurate, complete and understandable information to regulatory institutions and organizations on time. While carrying out all of our activities and operations, we take equal position with all public institutions and organizations, administrative organizations, non-governmental organizations and political parties without any benefit expectations and we fulfill our responsibilities with this responsibility.

ii.Our Responsibilities to Our Customers

We work with a proactive approach that focuses on customer satisfaction and responds to the needs and demands of our customers in the shortest time and in the most accurate way. We provide our services on time and in the conditions we promise; and we treat our customers with respect, honor, fairness, equality and courtesy.

We carefully protect confidential information of our customers. In relations with customers, no transaction may be carried out without the customer's knowledge, customer's weaknesses may not be exploited, and profit may not be sought by providing incomplete or incorrect information to the customer.

iii.Our Responsibilities to Our Shareholders

At YÜNSA, in line with the goal of creating value for our shareholders and giving priority to sustainability, we make our decisions based on known economic criteria, and we attach importance to the most efficient management of resources with an understanding of financial discipline and accountability.



We provide timely, accurate, complete and understandable information about the company's financial statements, strategies, investments and risk profile in our disclosures to the public and our shareholders. All meetings to be held with investors, financial analysts, members of the press, etc. are regulated by the relevant internal regulations, and we do not make any verbal or written statements on behalf of YÜNSA unless assigned to do so.

ıv. Our Responsibilities to Our Suppliers

We treat our suppliers and business partners fairly and respectfully, as expected from a good customer, and take due care to fulfill our obligations on time. We carefully protect the confidential information of the persons and organizations we do business with and our business partners.

v.Our Responsibilities to Our Competitors

We compete effectively only in legal and ethical areas and avoid unfair competition. As Yünsa, we support efforts to ensure the targeted competitive structure within the society.

vı. Our Responsibilities to Society and Humanity

The protection of democracy, human rights and the environment, social responsibility and the elimination of crime and corruption are very important to us. With the awareness of being a good citizen, we act sensitively as a pioneer in social issues and try to take part in non-governmental organizations and services for the public interest. We are sensitive to the traditions and cultures of Türkiye and the countries where we carry out international projects.

  • We act in compliance with the Labor Law and the covenants of the International Labor Organization (ILO) to which the Republic of Türkiye is a party, regarding not employing child labor and we ensure that our suppliers act in compliance within the scope of such legislation.

vıı. Our Responsibilities to Our Employees

We ensure that the personal rights of our employees are fully and properly utilized. We treat employees honestly and fairly, and commit to a non-discriminatory, safe and healthy working environment. We make the necessary efforts for the individual development of our employees, support them in volunteering for appropriate social and community activities in which they will take part with a sense of social responsibility, and observe the balance between business life and private life.


Policy on Creating and Maintaining a Fair Working Environment

Yünsa Yünlü Sanayi ve Ticaret A.Ş. considers the creation and maintenance of a fair working environment for employees as one of its top priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment in compliance with all relevant laws and regulations. The following codes of practice sets out the basic principles for creating and maintaining a fair working environment in the Company.


Codes of Practice

  1. Company practices comply with all applicable laws and regulations regarding employment and working life. Company employees also fulfill all legal requirements within the scope of their activities and act in accordance with legal regulations.
  2. Company’s human resources policies and practices ensure that all other practices such as recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. are fair.
  3. It is unacceptable to discriminate among employees within the organization based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons.
  4. By creating a positive and harmonious working environment that supports cooperation in the company, conflict is prevented and people with different beliefs, thoughts and opinions are ensured to work in harmony.
  5. We respect the private lives and personal spaces of the employees.



  1. In addition to all kinds of inviolabilities of employees, their physical, sexual and emotional inviolabilities are also protected.
    • It is against the law and ethical rules to violate the inviolability of individuals in any way through physical, sexual and/or emotional harassment in the workplace or any place where they are present for business purposes, and this crime is not tolerated by the Company in any way. In this context, all measures are taken to ensure that employees work in a work environment where their physical, sexual and emotional inviolability is protected.
    • Violation of a person's bodily inviolability and/or harassment of a person for sexual purposes without physical contact is defined as sexual assault/harassment. Accordingly, any behavior that can be considered within this definition is unacceptable.
    • “Psychological Harassment in the Workplace” (Mobbing), which is a set of malicious, intentional, negative attitudes and behaviors that are carried out by one or more than one person against another person(s) in the workplace, that continue systematically for a certain period of time, aiming to intimidate, pacify or dismiss from work, harming the personality values, professional status, social relations or health of the victim(s), is considered as one of the forms of harassment mentioned above.
  2. It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.
  3. Yünsa Yünlü Sanayi ve Ticaret A.Ş. acts sensitively as a pioneer in its responsibilities towards the society and humanity and takes all measures required by the legislation in order to ensure that the basic activities it carries out do not have negative impacts on the environment. It raises awareness and sensitivity of employees on this issue.


Policy for Trading of Company Shares

It is essential that the employees of Yünsa Yünlü Sanayi ve Ticaret A.Ş. comply with the legal regulations regarding the purchase and sale of Company shares and avoid situations that may create conflicts of interest. The following codes of practice sets out the principles to be applied by the Company's employees while trading the Company's shares.


Codes of Practice

  1. It is forbidden for those who are in a position to know information that has not been disclosed to the public to use such information to benefit themselves and/or third parties, i.e. insider trading.
  2. Persons who may engage in insider trading are the chairman and members of the board of directors, executives (managers and above) and auditors of the publicly traded company, as well as persons who are in a position to obtain information during the performance of their professions and duties, and persons who are in a position to obtain information directly or indirectly due to their contact with them.
  3. These persons may only buy and sell the Company's shares by using publicly disclosed information and for investment purposes (holding them for more than 6 months is considered investment purposes).
  4. The above-mentioned practices are also valid for the spouses and children of the employees, and the transactions made by their spouses and children are deemed to have been made by the employees.



Compliance with business ethics and related policies, procedures and instructions is the primary responsibility of all employees. In this regard, all Yünsa employees are responsible for;

  • Acting in compliance with laws and regulations under all circumstances,



  • Reading the Code of Business Ethics, knowing, understanding, internalizing and acting in accordance with the rules, principles and values contained therein,
  • Learning the general and job-related policies and procedures applicable to the company,
  • Consulting with their managers and Human Resources about potential violations involving themselves or others,
  • Reporting possible violations by themselves or others promptly, communicating reports on these matters to their managers, Human Resources and/or the Ethics Committee in writing or verbally (based on reliable sources, information and documents to the extent possible), either anonymously or anonymously,
  • Cooperating with the Ethics Committee in ethical investigations and keeping the information related to the investigation confidential.


E.1.Ways and Methods to be Followed While Making Ethical Decisions

You should follow the following steps and ask yourself these questions to guide you in deciding on a plan of action:

1.Identifying the Incident, Decision or Problem

  • Have you been asked to do something you think might be wrong?
  • Are you aware of something potentially illegal or unethical in your company or business partners?
  • Are you trying to make a decision and have doubts about how to behave in accordance with business ethics?

2.Think Before Deciding

  • Try to clearly identify and summarize the problem or question
  • Ask yourself why there is a dilemma
  • Consider the options, the consequences and who might be affected
  • Consult others

3.Decide on a Plan of Action

  • Identify your responsibilities
  • Review all relevant facts and information
  • Refer to appropriate company policies, procedures and professional standards
  • Assess the risks and think about how to mitigate them
  • Try to create the best plan of action
  • Consult others

4.Test Your Decision

  • Review the ethical questions to ask
  • Review your decisions within the framework of the company's core values
  • Make sure you take into account company policies, laws and professional standards
  • Consult others and consider their views in your plan of action

5.Continue with Determination

  • Share your decision with the relevant people with your reasons
  • Share your learnings and success story with others


E.2.4 Key Questions to Consider

  1. Does this activity/behavior comply with laws, rules and customs? (Standards)
    • Does it comply with professional standards?



  • Is it in accordance with the law?
  1. Is this activity/behavior balanced and fair? Would we be bothered if a competitor (someone else) did it? (Sense of justice)
    • Is that true for you?
  2. Would our company and stakeholders feel uncomfortable if all the details of this activity were made public? (Emotions and ethical values)
    • Would you feel embarrassed or ashamed if others knew you had done this?
    • Could it have negative consequences for you or your Company?
    • Who else might be affected (other employees within the company, you, shareholders, etc.)?
  3. To what extent does the “perceived reality” correspond to the “objective reality”?
    • How would it be reflected in the media?

What would a reasonable person think in the same circumstances?


E.3.Use of Social Media

Company employees may not;

  • Share data or information, practices, procedures, any information that may be considered confidential information for the Company, including the Company's customers, operation, business structure, organization, in their social media posts and/or profiles.
  • Share “personal” posts on Linkedin under the name of the Company, and “personal” photos and/or videos that may damage the employer's brand, prestige and reputation.
  • In all other social media accounts, Employees cannot include the Company's name in the section where they introduce themselves (“Bio”).
  • While using their own social media accounts, if they make personal posts with the company name, they may not share posts that damage the Company's brand, prestige, reputation and/or damage the reputation of the Company in the eyes of third parties.


F.Confidentiality and Unfair Competition

Company employees;

  • As a requirement of the Employment Contracts, may not share with third parties all kinds of documents, information, computer software, correspondence to be delivered electronically, drawings, industrial designs, technical, know-how, research/development information, including but not limited to all kinds of commercial, technical, financial, intellectual and industrial property and similar information that they have obtained in the workplace; and may not disclose them in any way, in writing and/or verbally, to any third person or third institutions/organizations, including but not limited to all kinds of social media sharing sites such as Facebook, Twitter, Youtube, Linkedin, Instagram, Whatsapp, etc., all kinds of blog pages and similar social media websites and all kinds of newspapers, journals, magazines, television channels, e-mails and similar press and broadcasting organs, academic research and articles written with academic research in educational and training institutions at all levels, and similar written and verbal disclosure situations.
  • They shall not take any action that would compete with the Company and shall not compete in any way, either explicitly or implicitly.
  • They are aware that it is one of their fundamental responsibilities to adhere to the principles of confidentiality in order not to put the company in a situation of unfair competition.







Company managers have additional responsibilities beyond the responsibilities defined for employees within the framework of business ethics rules. Accordingly, managers are responsible for;

  • Ensuring the creation and maintenance of a corporate culture and working environment that supports ethical rules,
  • Setting an example for the implementation of ethical rules with their behaviors and training their employees on ethical rules,
  • Supporting employees in communicating their questions, complaints and notifications regarding ethical rules,
  • Providing guidance on what to do when consulted, taking into account all notifications received and forwarding them to the Ethics Committee as soon as possible when deemed necessary,
  • Ensuring that the business processes under their responsibilities are structured in a way to minimize the risks related to ethical issues and applying the necessary methods and approaches to ensure compliance with ethical rules.



Ethics Consultant is responsible for;

  • Providing guidance and counseling on questions and issues communicated by employees regarding ethics within the company,
  • Contributing to the resolution of ethical nonconformities communicated to him/her and referring unresolved nonconformities to the Ethics Committee,
  • Reporting ethical questions and nonconformities to the Ethics Committee on a regular basis or when requested, together with their results,
  • Being the contact person in the investigations conducted by the Ethics Committee and providing the necessary support to the investigations,
  • Monitoring and tracking the effectiveness of the ethical practices carried out in the company and providing support in these practices.


Our Company's Ethics Consultant is the Internal Audit Manager.



  • Senior Management is responsible for the effective implementation of the Code of Business Ethics and the creation of a culture that supports it.

In cooperation with the Ethics Committee, it is responsible for;

  • Guaranteeing the confidentiality of complaints and notifications made within the framework of the Code of Ethics and protecting individuals after their reporting,
  • Ensuring the occupational safety of the reporting employees,
  • Ensuring that complaints and notifications are investigated in a timely, fair, consistent and sensitive manner and taking the necessary actions decisively as a result of violations.
  • Human Resources and Corporate Development Department is responsible for:
    • Informing employees about the Code of Ethics, providing trainings in certain periods in order to ensure the comprehensibility of policies and rules, and ensuring continuous communication of this issue with employees,



  • Ensuring that new employees read the code of ethics, are informed about it and sign the Employee Declaration,
  • Ensuring that all employees receive training on our Code of Business Ethics each year and renew their declarations by signing the Business Ethics Compliance Form.



If the employees are confronted with behaviors, practices, requests and decisions contrary to the Code of Business Ethics or if they learn that the legal regulations to which the Company is subject are violated, they first question this situation from an ethical point of view, ask themselves the questions specified in Article E1, and communicate their problems by calling or e-mailing the Ethics Committee in case of an unethical situation.


Ethics Committee is responsible for;

Investigating and resolving complaints and notifications of violations of the Code of Ethics. The Ethics Committee, which reports to the Deputy Chairman of the Board of Directors, consists of the Internal Audit Director (Chairman), the Company’s Attorney (Member) and the Human Resources and Corporate Development Manager. When the Ethics Committee needs to make a decision on any situation, at least two of the members of the committee, which consists of 3 members in total, must agree. Otherwise, the application must be submitted for the approval of the General Manager, whose own decision is necessary.


The Ethics Committee conducts its activities within the framework of the principles set out below:

  • It keeps the notifications and complaints and the identity of those making the notifications or complaints confidential.
  • Everyone who makes notifications to the Ethics Committee is under the protection of the Ethics Committee due to these notifications and cannot be subjected to pressure, discrimination or mobbing.
  • The Ethics Committee conducts the investigation as confidential as possible.
  • It is authorized to request information, documents and evidence related to the investigation directly from the unit in question. It may examine all kinds of information and documents it obtains only limited to the subject of the investigation.
  • The investigation process is recorded in writing from the beginning. Information, evidence and documents are attached to the report.
  • The report is signed by the chairman and members.
  • The investigation is handled in an expeditious manner and concluded as quickly as possible.
  • The decisions taken by the Board are implemented immediately.
  • Relevant departments and authorities are informed about the result.
  • The chairman and members of the Board act independently of and without being influenced by their department managers and the hierarchy within the organization while fulfilling their duties on this issue. They cannot be pressured or indoctrinated.
  • The Board may seek expert opinion if it deems necessary and may make use of experts during the investigation by taking measures not to violate the principles of confidentiality.
  • If the notification and complaint received by the ethics committee is related to one of the members of the ethics committee, the relevant person is excluded from the investigation. Other board members carry out these activities together. When such a situation is encountered, the process is carried out within the knowledge of the General Manager.


Employees can send any questions and notifications on ethical issues to the members of the ethics committee or to


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