CODE OF BUSINESS ETHICS

This regulation describes and explains Gülermak business and management ethics. All of directors, managers, and employees should take into account of business ethical conduct while they are fulfilling the requirements of job and responsibilities.

This code is designed:

  • To promote Board, directors and managers to give importance to the business ethics
  • To inform the staff on what kind of behaviour is not suitable in work
  • To report of non-ethic behaviours
  • To promote the values and principles it embodies and to deter any wrongdoing

It is obvious that any rules and prohibitions would not be sufficient to prevent a delinquency. The Code is crucial in ensuring that our directors, managers, officers and employees are aware of the standards we have set for Gülermak. They are expected to fulfil their job requirements and responsibilities while evaluate and judging in professional and objective way the faults in the management processes.

Conflict of Interest

All employees should pay attention for not causing any possibilities of conflict between their personal and Gülermak’s interests.

Conflicts of interest may occur in the following situations:

  • In case when one employee’s personal interest is conflicting or likely to conflict, with another employee’s personal interest or as a whole interests of Gülermak.
  • In case of happening or likely to happen an event deterring the duties to be fulfilled objectively and effectively.
  • In case of an employee’s using his position in order to take advantage in relation to his or to his relatives interest.

Occurrence of similar situations as listed above or even the probability of occurrences should be informed immediately to Head of Business Unit and/or General Manager.

Work Opportunities

All employees:

  • may not take advantage for themselves through the use of Gülermak property, information or position.
  • may not use Gülermak property, information or position for personal interest
  • may not compete with Gülermak (directly or indirectly).

Confidentiality

All employees who have access to confidential information provided by Gülermak, other employees or clients are legally responsible for maintaining the confidentiality of given information.

Confidential information is any data or information that is not public or that may have negative impact on Gülermak and its client’s interests, or that can be used by competitors.

Fair Treatment

All employees should act fairly and equally to Gülermak’s clients, sub-contractors and suppliers. Nobody can take advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

Protection and Proper use of Company Assets

All employees are responsible for the proper and efficient use of company assets. Theft, negligence and waste have direct negative impact on Gülermak’s profitability. Company assets should be used only for legitimate business purposes.

Accuracy of Recording and Reporting

All employees are obliged to use applicable internal systems for use of records, accounts and internal audits and statements. Manipulation of Gülermak’s records in any way is prohibited.

All reports, documents and correspondences, should be stored and processed in complete, correct, accurate, and understandable way.

Compliance with Law Rules and Regulations

All employees, who work for Gülermak, have to work according to all applicable laws, and mandatory and regulatory rules and regulations.

Contracts with Public Administrations

Contracts made with public administrations, may apply special, complex laws, rules and regulations. Unfulfilling the complete regulations may constitute a criminal offense. Therefore, in order to fulfil the complete regulations, it is advised to request support from appropriate people within the company or, if necessary from appropriate legal institutes or consultants.

Reporting of Inappropriate and not Ethics Behaviour

All employees should encourage all other employees to work according to Code of Business Ethics and in case of violations or any doubts should report immediately to their supervisors/managers and directors.

All directors and managers are responsible for the reporting violations of ethics rules to the Head of Business Unit and/or General Manager. All violations will be examined by the Head of Business Unit and/or General Manager and then necessary sanctions shall be applied. Gülermak, regardless of the intention, will not allow any retaliation against any violation, reporting of inappropriate and unethical behaviours.

Modifications and Waiver

Modifications or waivers of above rules may be done only by the Board of Directors with recommendations of Management of Business unit.

Kemal Tahir Güleryüz
Chairman

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