125 Mutlukent, Çankaya, Ankara. 06585 

  Phone: +90 312 210 01 00

  Fax: +90 312 210 00 22

CLASSIFIED NATIONAL SECURITY INFORMATION

Only employees with proper government clearance and a need to know have access to classified national security information. Government regulations outlined in company instructions for safeguarding must be followed. Disclosing such information, without authorization, even after
leaving employment, is a violation of law and this code.

Adverse information about employees having government clearance must be reported to the Security or Law Departments’ representatives having responsibility for clearances.

Cash and Bank Accounts

All cash and bank account transactions must be handled so as to avoid any question or suspicion of impropriety. All cash transactions must be recorded in the company’s books of account. All accounts of company funds, except authorized imprest funds, shall be established and maintained in the name of the company or one of its subsidiaries and might be opened or closed only on the authority of the company’s Board of Directors. Imprest funds must be maintained in the name of the custodian and the custodian is wholly responsible for these funds. All cash received shall be promptly recorded and deposited in a company or subsidiary bank account. No funds shall be maintained in the form of cash, except authorized petty cash, and no company shall maintain an anonymous (numbered) account at any bank.

Payments into numbered bank accounts by the company might leave that company open to suspicion of participation in a possibly improper transaction. Therefore, no disbursements of any nature might be made into numbered bank accounts or other accounts not clearly identified to the company as to their ownership.

No payments can be made in cash (currency) other than regular, approved cash payrolls and normal disbursements from petty cash supported by signed receipts or other appropriate documentation. Further, corporate checks shall not be written to “cash,” “bearer” or similar designations.

COMPANY ASSETS AND TRANSACTIONS

Compliance with prescribed accounting procedures is required at all times. Employees having control over company assets and transactions are expected to handle them with the strictest integrity and ensure that all transactions are executed in accordance with management’s authorization. All transactions shall be accurately and fairly recorded in reasonable detail in the company’s accounting records.

Employees are personally accountable for company funds over which they have control. Employees who spend company funds should ensure the company receives good value in return and must maintain accurate records of such expenditures. Employees who approve or certify the correctness of a bill or voucher should know that the purchase and amount are proper and correct. Obtaining or creating “false” invoices or other misleading documentation or the invention or use of fictitious sales, purchases, services, loans, entities or other financial arrangements is prohibited.

Employees must pay for personal telephone calls and use, except to the extent that specifically defined benefit programs or allowances otherwise provide.

Expense Reimbursement

Expense actually incurred by an employee in performing company business must be documented on expense reports in accordance with company procedures. In preparing expense reports, employees should review these procedures for the documentation in order to be reimbursed for business expenses.

Company Credit Card

Company credit cards are provided to employees for convenience in conducting company business. No personal expenses can be charged on company credit cards except as specifically authorized by company procedures. Any charged personal expenses must be paid promptly by the employee. Company credit cards should not be used to avoid preparing documentation for direct payment to vendors. Where allowed by local law, charges on company credit cards for which a properly approved expense report has not been received at the time of an employee’s termination of employment might be deducted from the employee’s last paycheck. The company will pursue repayment by the employee of any amounts it has to pay on the employee’s behalf.

Software and Computers

Computerized information and computer software appear intangible, but they are valuable assets of the company and must be protected from misuse, theft, fraud, loss and unauthorized use or disposal, just as any other company property.

Use of mainframe computers must be customer service or job related. Employees cannot access company records of any kind for their personal use. Misappropriation of computer space, time or software includes, but is not limited to, using a computer to create or run unauthorized jobs, operating a computer in an unauthorized mode or intentionally causing any kind of operational failure.

Personal computers can be used for company-sanctioned education programs as well as personal use incidental to company business use with the permission of your supervisor. However, personal use cannot be allowed for personal financial gain.

It is also understood that personal computers will occasionally be used at home with the permission of your supervisor.