125 Mutlukent, Çankaya, Ankara. 06585 

  Phone: +90 312 210 01 00

  Fax: +90 312 210 00 22

Code of conduct

DISCIPLINE

Violation of this code can result in serious consequences for the company, its image, credibility and confidence of its customers and can include substantial fines and restrictions on future operations as well as the possibility of fines and prison sentences for individual employees. Therefore, it is necessary that the company ensure that there will be no violations. Employees should recognize that it is in their best interest, as well as the company’s, to follow this code carefully.

The amount of any money involved in a violation might be immaterial in assessing the seriousness of a violation since, in some cases, heavy penalties might be assessed against the company for a violation involving a relatively small amount of money, or no money.

Disciplinary action should be coordinated with the appropriate Human Resources representatives. The overall seriousness of the matter will be considered in setting the disciplinary action to be taken against an individual employee. Such action, which might be reviewed with the appropriate Human Resources organization, might include:

  • Reprimand
  • Probation 
  • Suspension 
  • Reduction in salary
  • Demotion
  • Combination of the above
  • Dismissal In addition, individual cases might involve: 
  • Reimbursement of losses or damages
  • Referral for criminal prosecution or civil action
  • Combination of the above

Disciplinary action might also be taken against supervisors or executives who condone, permit or have knowledge of illegal or unethical conduct by those reporting to them and do not take corrective action. Disciplinary action might also be taken against employees who make false statements in connection with investigations of violations of this code. The company in its sole discretion will determine the disciplinary action appropriate to a given matter.

The listing of possible actions is informative only and does not bind the company to follow any particular disciplinary steps, process or procedure. The company’s rules and regulations regarding proper employee conduct will not be waived in any respect. Violation is cause for disciplinary action including dismissal.

All employees will be held to the standards of conduct described in this booklet. The company never has and never will authorize any employee to commit an act that violates this code or to direct a subordinate to do so. With that understood, it is not possible to justify commission of such an act by saying someone directed it in higher management.

COMPLIANCE LETTER AND CODE OF CONDUCT QUESTIONNAIRE

Annually, all officers of the company will represent in writing that there are no violations of this code known to the officer, after the exercise of reasonable diligence, or if such violations have been committed, to disclose such violations in a format to be specified. Annually, each employee will review the Code of Business Ethics and Conduct, sign the code’s Acknowledgment form and complete and sign the Conflict of Interest Questionnaire. If the employee’s circumstances change at any time, a new Conflict of Interest Questionnaire or letter of explanation must be completed.The Code of Business Ethics and Conduct Acknowledgment form should be signed and given to your supervisor for inclusion in your personnel file.