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    BUSINESS ETHICS RULES FOR SETAŞ INŞAAT 

    What is the content of this study? 

    SETAŞ INŞAAT at all times depends on the highest moral standards in all the relationships between our employees, customers, and the society in which we live as well as the companies, selling goods and services to us, and our shareholders. We are proud of our attachment to integrity, equality and social responsibility. Moral principles and values lead the way for us in all the works we do: 

    Honesty: To remain faithful to reality with all our employees, to act honestly and frankly in the face of each other, our customers, the communities in which we act, our sources of supply and our shareholders. 

    Integrity: To say what we mean to say, to deliver the product we have given promise of and to defend what we believe is true. 

    Respect: To act respectfully and equally to each other with the awareness that the labor force of our company consists of differing individuals and every single individual is unique in himself. 

    Confidence: To give confidence by establishing an open and sincere communication through a team work. 

    Responsibility: If there is any behavior against our regulations and the company principles, to express them without hesitation, openly and to notify the persons in charge; in case of suspicion, to try to get explanatory and guiding information. 

    Awareness of Citizenship: To abide by the laws of the Republic of Turley and the foreign countries with which we conduct business and to fulfill the duties with which we are liable in order to improve the society in which we live. 

    This study aims at introducing the business management principles, including the responsibilities of our employees in the face of the company, to you in a clear manner. “Business Ethics Rules” consists of all the managers and employees of the company and subsidiary companies with inclusion of the Members of the Board of Directors; all the said people will be given as “employees” below. 

    Responsibility of each of us as employees is to protect the principles of honesty and ethical business mentality. Our liability in the relationships with others is to be honest, reliable, trustworthy and to abide by the ethical business rules at every single stage of our business. 

    The objective of the business ethics is to have a common mentality in terms of what is expected from us or not with our employees in the fields with which we are responsible let alone the applicable regulations and rules in our company. The said studies make up the work ethics principles, defining us as a company and determine some practical and guiding rules to help us capture and keep track of these principles. However, it is not possible that every single matter and detail takes place in this study. These rules have been designed to include the most frequently encountered matters and are not a comprehensive book of rules. 

    Please read this ethics rules of our company, spare time to think on it and make effort to work by observing them. We suggest that you apply to your manager and the Directorate of Human Resources immediately in case of your inquiries about the meaning of these rules and your concerns relating to the possible ethical violations at the workplace. 

    The main principle of this study may be summarized as below: 
    “With the title of the representative of the company, we should at all times and in every matter act honestly, equally and respectfully.” 


    OUR BUSINESS ETHICS RULES 

    A- Conflict of Interests 

    It constitutes the basis that SETAŞ employees are away from cases, which may lead to a conflict of interests. Use of the company resources, name, identity and power for personal interests; to abstain from cases, which may affect the name and image of the organization adversely, are among the most significant responsibilities of all employees. Your ability to make a decision is one of the most valuable assets of yours. Whereas, conflict of interests is a hindrance to your ability to make a decision. You, as the employee of SETAŞ, is expected to act in accordance with the interests of the company. 

    • They abstain from leading to conflict of interests or cases appearing so in favor of themselves or their kinsmen, and they do not take place in the decision making process in the matters relating to the interests of them or their kinsmen. 

    • They do not establish any financial relationships with the customers and suppliers, and they do not obtain personal benefits by use of the business relationships. 

    • They do not surrender to any pressure possible to give results against the company, they do not obtain personal benefits from customers/suppliers, they do not transfer benefits by establishment of an agency relationship between customers/suppliers. 

    • They use their time and effort for the institution. They do not assume any other responsibility, which will institute a case of conflict of interests and they may not work on behalf of any other real or legal person other than SETAŞ. 

    • They may not use the information, which they have obtained as a result of their duties, by leading to undeserved gain. 

    • They may not have an effect on the promotion or awarding decisions for their spouses or relatives within the company or the subsidiaries. 

    • In case of an affinity relation in-between the employees, there should not be a horizontal or vertical organizational connection in-between them at the stages of employment, rotation, promotion and appointment. 


    B- Accuracy of the Records 

    Accurate and well-protected work records are necessary and important in order to conduct our work. Within this framework, the employees are responsible for providing accuracy and law conformity of records and documents in all kinds of transactions, which they conduct in the name of SETAŞ. The said records are the basis for operation of the company activities and the company’s fulfillment of its liabilities in the face of its employees, suppliers, customers and public authorities. 

    C- Use of Company Assets and Resources 

    The assets of the company are for the company use and may not be used for personal purposes. All kinds of goods, assets, equipment, vehicles, computers, computer programmes etc., which are owned by the company and which are provided to the part of the employee to conduct the daily works, are delivered with the fixture delivery forms and recorded and may not be used for personal interests of oneself or another person by any employee. 

    Principle of “economization in all matters” is applied by all employees. The employees should be aware of the fact that benefiting from company assets for personal purposes intentionally is a violation of “Business Ethics Rules”. 

    Establishment of personal financial relationships with the persons and institutions, conducting business in the name of the company, trying to obtain interest and to observe personal interest in the agreements concluded is of the meaning that the material and immaterial assets of the company are in indirect use and it is absolutely inconvenient that such kind of environment is created and/or encountered by way of actions. 

    Employees of SETAŞ may not act as members or auditors of the board of directors in the companies out of the group companies without approval of the Board of Directors; may not take place in the companies, which are competitors or with which the company is in a business relationship. They may work in the non-profit-making organizations and universities with social responsibility and support based duties with written approval of the management if it does not interfere with its duty within the company. 


    D- Relationships with Customers and Suppliers 

    “To provide our customers with the best quality service as rapidly and economically as possible” is among the objectives of SETAŞ A.Ş. All our employees are attentive to being right, consistent, reliable and assisting in the relationships with those who are in a commercial relationship with our company and our customers. They pay maximum heed to an efficient information transfer with our customers and our suppliers. Each one of our employees has the title of representative of SETAŞ A.Ş. in all circumstances. We are of the belief that our success depends on the relationships with our customers, which are based on honesty, morality and mutual trust. 

    E- Policy of Gift Accepting and Giving 

    It constitutes the basis that SETAŞ employees do not accept gifts or benefits, which will affect their neutrality, decisions and behavior, and besides they do not make direct or indirect intervention of providing gifts and benefits to 3rd persons and institutions, which will create such an effect. The employees may not ask for gifts from other persons and/or institutions with which the company is in a commercial business relationship and may not ask for it implicitly. They may not accept any gifts, cash amounts, cheques, immovable properties, free holidays, special discounts etc., which will put the company under obligation. 

    The identity of the gifts and promotional materials to be given to customers, sellers and other 3rd persons with whom there is a business relationship by the company will be approved by the top management of the company. 

    F- Protection of Information 

    Utmost importance is attached to confidentiality of the information relating to the company, which is confidential and/or of a nature of a trade secret, as well as to information and documents belonging to customers. Such kind of information may by no means be used for personal purposes and may be shared with public by our employees. 
    Protection of the information, which belongs to the company but which is not open to public is the responsibility of employees. 

    G- Electronic Mail 

    Electronic mail should not be used for occupational purposes. It should not be used for illegal and immoral etc. messages, which will leave yourself and/or the company in a difficult situation. 


    H- Respect at the Workplace and Business Life 

    SETAŞ employees act with respect to each other. No SETAŞ employee may act by creating unease to other employees, customers or suppliers or by giving damage to the goods of others. 

    Within the structure of SETAŞ, private and family life is given respect. The company is liable with providing a secure, healthy and efficient working environment. The company is attentive to protection of personal information of the company employees. Necessary trainings are given in order for the employees to reach the target performance level with constant development in mind. 

    Within the company, everyone working in the company is accepted equal without making a distinction on account of race, language, belief, age, sex, nationality, disability and other categories under legal protection. 

    All kinds of actions, which are undesirable, which are not welcomed good and which are left unresponded by the other party, are within the scope of harassment. All kinds of actions, which are not welcomed good by the other employee, which include an expectation with a sexual message or which will arouse the feeling of threat and compromise, are deemed as harassment. All kinds of assaultive and scornful actions due to the disability of an employee having a physical disability is taken into the scope of the disability harassment. Within this framework, all the employees are attentive in their actions with each other. 

    I- Prevention of Undesirable Behavior at the Workplace Use of the Status Power at the Workplace 

    Abuse of the status power may stem from the abuse of the individual power (title, physical, personal, age) or collective power (power arising from the numerical majority) of the employee. Welcoming the reasonable and logical mistakes made by the employee with a proper and positive manner as well as assessments aiming for the development of the employees within the framework of the performance system etc. make up the cases in which the status power is not a matter of abuse. 

    Wearying, Setting as the Target, Selecting as the Victim 

    We all have the right of being respected and human dignity. Any action, which is possible to violate it, and any form of sexual harassment are not acceptable. 

    No actions and rumours, which will leave the employee alone in the company, should be adopted, no target should be set, and wearying actions, which are possible to create a psychological pressure, should be abstained from. Systematic and planned actions with the purpose of alienating the target person from the work, reducing the level of his performance and leading to his resignation may be given as an example (for instance: criticizing the private life of the employee, constantly interrupting him in groups, constantly scolding him before other employees, ignoring his success etc.) 

    SETAŞ takes all kinds of precautions in order to prevent this and such kind of actions and expects all its employees to show utmost attention. 

    Environmental Sensitivity 

    Protection of the world in which we live is of vital importance. 

    As SETAŞ, we are cognizant of importance and value of a healthy and clean environment. Our employees should apply the principles relating to matters of health, safety and environment accurately at all the locations, where our company conducts activity. 

    We are attentive to planning, constructing and operating workplaces, which protect our employees and our current resources. This attention, at the same time, includes use of adequate protective equipment, taking precautions and safe conduct of works as well.