125 Mutlukent, Çankaya, Ankara. 06585 

  Phone: +90 312 210 01 00

  Fax: +90 312 210 00 22

Code of conduct

OUTSIDE EMPLOYMENT 

Employees must not be employed outside the company:

In any business that competes with or provides services to the company or its subsidiaries, and/or

  • In a manner which would affect their objectivity in carrying out their company responsibilities and/or
  • Where the outside employment would conflict with scheduled hours, including overtime, or the performance of the company assignments. Employees must not use company time, materials, information or other assets in connection with outside employment.

Relationships with Suppliers and Customers

Business transactions must be entered into solely for the best interests of the company. No employee can, directly or indirectly, benefit from his position as an employee or from any sale, purchase or other activity of the company. Employees should avoid situations involving a conflict or the appearance of conflict between duty to the company and self-interest.

No employee who deals with individuals or organizations doing or seeking to do business with the company, or who makes recommendations with respect to such dealings, should:

  • Serve as an officer, director, employee or consultant; or
  • Own a substantial interest in any competitor of the company, or any organization doing or seeking to do business with the company. Substantial interest means an economic interest that might influence or reasonably be thought to influence judgment or action, but shall not include an investment representing less than 1% of a class of outstanding securities of a publicly held corporation. Every employee must complete the Conflict of Interest Questionnaire included with this book. In addition, no employee who deals with individuals or organizations doing or seeking to do business with the company, or who makes recommendations with respect to such dealings, might:
  • Have any other direct or indirect personal interest in any business transactions with the company (other than customary employee purchases of company products and services as consumers and transactions where the interest arises solely by reason of the employee relationship or that of a holder of securities);
  • Provide telecommunications or information service or equipment, either directly or as a reseller in a manner that would place the objectivity or integrity of the company in question.


Our policy is that employees will not do business on behalf of the company with a close personal friend or relative; however, recognizing that these transactions do occur, they must be reported on the Conflict of Interest Questionnaire.

This policy is applicable equally to the members of the immediate family of each employee, which normally includes your spouse, children and their spouses, and the father, mother, sisters and brothers of yourself and your household.

Employment of Relatives

Relatives of employees will not be employed on a permanent or temporary basis by the company where the relative directly reports to the employee or the employee exercises any direct influence with respect to the relative’s hiring, placement, promotions, evaluations or pay.

Confidential Information and Privacy of Communications

Confidential Information

Confidential information includes all information, whether technical, business, financial or otherwise concerning the company, which the company treats as confidential or secret and/or which is not available or is not made available publicly. It also includes any private information of, or relating to, customer records, fellow employees, other persons or other companies, and national security information obtained by virtue of the employee’s position. Company policy and various laws protect the integrity of the company’s confidential information which must not be divulged except in strict accordance with established company policies and procedures. The obligation not to divulge confidential company information is in effect even though material might not be specifically identified as confidential and the obligation exists during and continues after employment with the company.

A few examples of prohibited conduct are:

  • Selling or otherwise using, divulging or transmitting confidential company information;
  • Using confidential company information to knowingly convert a company business opportunity for personal use;
  • Using confidential company information to acquire real estate which the employee knows is of interest to the company;
  • Using, divulging or transmitting confidential company information in the course of outside
  • employment or other relationship or any succeeding employment or other relationship at any time; and
  • Trading in the company stocks, or the stocks of any company, based on information which has not been disclosed to the public or divulging such information to others sothat they might trade in such stock. Insider trading is prohibited by company policy and federal and state law.

Employees shall not seek out, accept or use any confidential company information of or from a competitor of the company. In particular, should we hire an employee who previously worked for a competitor, we must neither accept nor solicit confidential information concerning that competitor from our employee.