Anti-Bribery and Anti-Corruption Policy

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Goal

We adopt a “zero tolerance” policy against bribery and corruption, and conduct our activities in a fair, legal and ethical manner. Our Anti-Bribery and Anti-Corruption Policy covers the compliance of all our employees with the anti-bribery and anti-corruption laws, ethical principles and other relevant international standards in all countries where we operate.

Scope

Our Anti-Bribery and Anti-Corruption Policy applies to all of our employees, including Board of Directors, suppliers and their employees, and business partners who provide external services to our company.

Responsibilities

The implementation and update of the Anti-Bribery and Anti-Corruption Policy is under the authority, duty and responsibility of the Board of Directors.

All our employees are responsible;

• to comply with the policies determined by the Board of Directors,

• to effectively manage the risks related to their field of activity,

• to work in compliance with the relevant legal regulations,

• to notify the senior management in case of a behavior, activity or practice contrary to this policy.

Code of Practice

1. Bribery and Corruption

Bribe may appear in the forms as directly or indirectly to gain personal advantage, promise, authorize, request, etc. Bribery and corruption of any form, whether carried out directly or indirectly through another party, is strictly prohibited. 

Corruption is a criminal offense in all areas where we operate.

2. Gifts and Hospitality

Gifts, hospitality and entertainment should always be proportionate and fall within reasonable bounds. Gifts and hospitality must be for a legitimate purpose and must not create a conflict of interest or perception.

3. Facilitation Payments

Facilitating payments are not allowed to secure or expedite a routine business or process (permission, license, tender, etc.) with public institutions.

4. Donations

Our employees must ensure that their donations are bona fide or made to real charities and are not used to conceal bribery.

All charitable donations and social responsibility expenditures require written approval from the Board of Directors.

5. Record Keeping

All kinds of accounts, invoices and documents regarding relations with third parties (customers, suppliers, other service providers, etc.) are recorded and preserved in a complete, transparent, precise, fair and accurate manner.

Internal control systems have been established to prevent unregistered transactions.

Care is taken not to make any changes to the accounting or similar commercial records of any transaction and not to deviate from the facts.

6. Representation and Hospitality

DORUK ENDÜSTRİ may carry out limited representation and entertainment activities related to accommodation and dinner invitations for the purpose of developing commercial relations and establishing a commercial communication network.

Event activities are reasonably exercised, and ensured that representation and entertainment do not precede a fundamental and important decision-making process.

7. Training and Communication

Our Anti-Bribery and Anti-Corruption Policy has been announced to our employees and is always accessible via the corporate website.

Trainings are organized for our employees to raise awareness of bribery and corruption.

8. Notice of Violations

Our employees can report violations through internal reporting channels (complaint boxes, Disciplinary Board, etc.). In case of detection of inappropriate behavior, necessary sanctions are applied.