Business Ethics Principles
ENTRANCE
Business Ethics Principles are designed to apply the high standards of ethical behavior of Uğur Teneke Ambalaj ve Plastik San.A.Ş. to its corporate governance structure and to ensure that our ways of doing business are compatible with our values and the existing legal rules in the country we are in.
The Business Ethics Principles Program has three operational bases:
• Prevention - We work to spread and establish a culture of honest work at all levels.
• Detection - We encourage our employees to report nonconformities and be the voice of our values.
• Respond - We have the necessary infrastructure to properly investigate violations and handle proven violations with a standard and fair approach and apply relevant sanctions if necessary. We use what we learn from these experiences to constantly improve ourselves.
We carry out all our operations with honesty, respect for human rights and in accordance with the law. We expect all our employees and business partners to adopt these rules and act accordingly. Our leaders in our organization are responsible for leading our employees by displaying exemplary behavior and making business decisions in accordance with the Business Ethics Principles and relevant policies.
In addition to determining our standard of conduct, the Code of Business Ethics and related policies include rules on combating corruption, ensure that our employees work in respectful working environments, set standards for the protection of information and data, and guide us on the behavioral model we will adopt in our external relations.
Working with integrity and high standards of business ethics is Uğur Teneke Ambalaj ve Plastik San.A.Ş.'s absolute way of doing business, and it is of great importance to adopt some principles to adopt this method.
These principles:
• Acting professionally,
• Doing business honestly and in accordance with the law
• Protecting our customers' reputation as well as our own
• Being respectful to people and the environment
• Acting with social responsibility awareness
• Working together and paying attention to the way we work
• Respecting the rights of our employees and providing them with a good and safe working environment
• To ensure that our employees' talents are used and developed in the best possible way, and to create a participatory work environment that provides equal opportunities for everyone to develop their talents and skills.
• Encouraging employees to contribute to the planning and management of work
• Decisions regarding employees; to give according to the employee's qualifications, performance, skills and experience
• Considering the ethical dimensions of our activities
• Never tolerate any form of corruption, including bribery.
Business Ethics Principles, Internal Personnel Regulations and other Uğur Teneke Ambalaj ve Plastik San. Inc. It is complementary to, and should be read in conjunction with, documents that can be adapted to help implement the principles contained in its policies and procedures.
The Company may make changes to its Business Ethics from time to time to reflect changes in relevant laws and regulations. All managers and employees are responsible for learning and becoming aware of the updates made to the Business Ethics Principles.
1. BUSINESS ETHICS PRINCIPLES
A- GENERAL
Uğur Teneke Ambalaj ve Plastik San. Inc. It is essential that its employees stay away from situations that may create a conflict of interest. It is the most important responsibility of all employees not to use company resources, name, identity and power for personal benefit and to avoid situations that will negatively affect the name and image of the company.
Application basics
a) Conflict of Interest
• Employees; Under no circumstances does it enter into business relationships with family members, friends or other third parties that are contrary to the interests of the company. Business relations of company partners in this context are subject to joint permission.
• Uğur Teneke Ambalaj ve Plastik San. Inc. employees, immediate family members of Uğur Teneke Ambalaj ve Plastik San. They should also be careful about conflicts of interest that may arise due to working for A.Ş.'s competitors.
• Uğur Teneke Ambalaj ve Plastik San. Inc. It is subject to management approval for its employees to work directly or indirectly, under any name, for another person and/or institution, within or outside working hours, in return for a fee or similar benefit.
• Managers who have to make a hiring decision cannot hire their spouses and close relatives.
• Employees, Uğur Teneke Ambalaj ve Plastik San. Inc. In addition, he/she may personally provide material or moral aid and/or donations to third parties and take part in charitable associations.
• Company employees cannot work a second paid job on working days, weekdays, national holidays, public holidays, or annual paid leave. Information and notification to the Human Resources Department for works carried out in return for copyright through cultural, artistic or scientific studies.
is said. In addition, our employees must obtain the written approval of the Business Manager if they are offered a consultancy or similar position that will require payment of a fee, or if they have a direct or indirect share in a company at a level that will have a say in its management.
On the other hand, our employees can engage in voluntary activities (legally established charities, associations or non-governmental organizations, etc.) in a way that does not disrupt their duties and responsibilities in the institution. However, the corporate title and location cannot be used during this activity.
b) Abuse of Office
• Uğur Teneke Ambalaj ve Plastik San. It is unacceptable that it harms A.Ş.
• Employees Uğur Teneke Ambalaj ve Plastik San. A.Ş. cannot gain personal profit directly or indirectly from its activities and all transactions and contracts to which it is a party.
• Employees must comply with morality, law and Uğur Teneke Ambalaj ve Plastik San. Inc. Personnel cannot engage in acts or behaviors contrary to the Internal Regulations.
• Information held by employees due to their duties in the company cannot be used for personal benefit or the benefit of anyone else.
c) Resource Usage
• As a general rule, personal use of company assets should be avoided.
• Uğur Teneke Ambalaj ve Plastik San. Inc. In the resource uses to be made on behalf of Uğur Teneke Ambalaj ve Plastik San. Inc. interests are taken into account. Uğur Teneke Ambalaj ve Plastik San. Inc. Uğur Teneke Ambalaj ve Plastik San. Inc. assets, facilities and personnel Uğur Teneke Ambalaj ve Plastik San. Inc. cannot be used outside.
• Sources Uğur Teneke Ambalaj ve Plastik San. Inc. Proper use of time for one's benefit also requires correct use of time. During business hours, Uğur Teneke Ambalaj ve Plastik San. Inc. Its employees use their time well and do not spare time for their private affairs during working hours. Managers cannot assign employees to their personal work.
• It is essential that no private visitors are allowed during working hours. Employees are required to complete interviews for essential visitors within a reasonable period of time, in relation to the subject of the visit and in a way that does not hinder the workflow.
d) Relations with Institutions, Organizations and Individuals with whom we have commercial relations
• Uğur Teneke Ambalaj ve Plastik San. Inc. No special business relationships can be entered into with customers, subcontractors or suppliers and other persons and/or organizations with which the company has commercial relations, and no money and/or goods/services can be borrowed or given for personal purposes.
• In relations with customers, no transaction can be carried out without the customer's information, customer weaknesses cannot be exploited, and incomplete or incorrect information cannot be given to the customer.
• Uğur Teneke Ambalaj ve Plastik San. Inc. Its personnel cannot request or imply gifts from other persons and/or organizations with which the company has commercial relations; Uğur Teneke Ambalaj ve Plastik San. No gifts, money, checks, property, free holidays, special discounts, etc. that would put A.Ş. under any liability. cannot accept. Uğur Teneke Ambalaj ve Plastik San. Inc. Personal aid or donations cannot be accepted from any person or organization that has a business relationship with.
e) Relations with the Media
• Giving a statement to any broadcasting organization, conducting an interview, seminar-conference, etc. Participating as a speaker is subject to the approval of the company's senior management. No personal gain can be derived from these activities.
• Employees, in their social media profiles and posts, Uğur Teneke Ambalaj ve Plastik San. Inc. does not act in a way that is inconsistent with his identity; The company, its partners, employees and customers cannot engage in derogatory or humiliating behavior or posts.
• When employees share information or opinions on their own behalf, they do not refer to their position as an employee or the content is shared by Uğur Teneke Ambalaj ve Plastik San. Inc. It cannot make any reference to . For this purpose, Uğur Teneke Ambalaj ve Plastik San. Inc. Cannot use any written or visual material that can be associated with.
f) Represent the company
• Uğur Teneke Ambalaj ve Plastik San. The authority and responsibility to represent A.Ş. is carried out by the Chairman of the Board of Directors, the Business Manager or the persons authorized by these persons.
g) Accepting and Giving Gifts
• Uğur Teneke Ambalaj ve Plastik San. Inc. It is forbidden for its employees to receive any benefits or gifts of high economic value that affect or may affect their impartiality, performance, and decision-making while working.
However, small and low-value gifts given by business owners for advertising purposes on special days of the year are outside the scope of this article.
• In seminars and similar organizations attended on behalf of the company, awards, shields, etc., which have symbolic value and are given as a souvenir of the day, other than money. gifts can be purchased.
• Company employees receive unrequited or loaned money from subcontractors, suppliers, consultants, competitors or customers.
It is forbidden to accept it.
• Receiving, giving or offering bribes and/or kickbacks is unacceptable under any circumstances.
• If you want to give a gift to any Public Official or employee, T.R. Action must be taken in accordance with the current decision of the Public Servants Ethics Committee on this subject, which is available on the website http://www.etik.gov.tr.
h) Corruption and Bribery
• Corruption; It is the abuse of the authority possessed by one's position for the purpose of gaining any kind of gain, directly or indirectly.
• Bribery means providing, offering or promising a benefit, directly or through intermediaries, in order to make a person do, have someone do, not do, speed up or slow down something related to the performance of his/her duty; It is the act of providing benefits to oneself or to the party requesting this, or to someone else due to this relationship, within the framework of an agreement reached with another person to act contrary to the requirements of his/her duty, by means such as requesting or accepting, or mediating these.
• Uğur Teneke Ambalaj ve Plastik San. Regardless of the purpose, accepting or giving bribes is strictly prohibited and unacceptable at A.Ş.
i) Money Laundering
In accordance with the relevant legislation in force, especially the Law No. 5549 on the Prevention of Laundering Proceeds of Crime, Company employees cannot be involved in or condone money laundering activities, and are obliged to report any activities they know or suspect to the relevant authorities. In accordance with the same legislation, the Company's products and services cannot be used to launder proceeds of crime. From this point;
• Company personnel are trained to combat such crimes,
• By recording customer identities and addresses, the records are stored and verified physically and electronically.
• The consistency of documents and information is examined,
• Customer financial situation and professional field of activity, location of activity, contract profile and capacity are recorded.
• Customer relationships should not be established with individuals and organizations that avoid providing information and documents, give false information, or whose information cannot be verified.
• Contracts must be made with real names and titles
j) Substance Abuse
• Substance abuse puts us all in danger by limiting our ability to work safely.
Therefore, while under the influence of alcohol, illegal substances, abused prescription drugs or non-prescription drugs, Uğur Teneke Ambalaj ve Plastik San. Inc. No work may be done on its behalf under any circumstances. This situation applies to Uğur Teneke Ambalaj ve Plastik San. including overtime hours or hours outside the company premises. Inc. Uğur Teneke Ambalaj ve Plastik San. Inc. It is valid for every moment you work for. It is up to individuals to consume alcohol in moderation, in accordance with the environment and concept, at company meetings and business dinners.
k) Business Meals
• Persons authorized to represent the company can provide and receive entertainment, treats and meals at acceptable standards in the business world. Whether or not a dinner invitation is made, care should be taken to act in accordance with the purpose of the invitation. In principle, it is essential that a business dinner invitation be held in a place suitable for the business dinner concept and the location of the participants. It is up to individuals to consume alcohol in moderation, in accordance with the environment and concept, at company meetings and business dinners.
l) Activities with Political Content
• Our company respects the right of its employees to individually participate in political events, but those who participate in political events must clearly state that they do not represent the company. The following are expected from our employees who take part in political activities:
- To make clear the fact that it does not represent the company in any way.
- Strictly avoid the use of company resources (including Company time, phones, paper, e-mail and other assets) in carrying out or supporting personal political activities.
m) Order of Records
Our employees are primarily responsible for keeping and storing all records within their responsibilities and authorities accurately, on time and in accordance with the law. Whether the records in question are in printed or electronic form does not make any difference in the implementation of this article.
n) Fair Competition
Uğur Teneke Ambalaj ve Plastik San. Inc. Being aware of the importance of the existence of a competitive market, we undertake to comply with all rules and regulations regarding competition and transparency in all commercial transactions we carry out. Our employees are responsible for complying with the competition laws in all markets in which we operate and not violating the intellectual property rights of third parties.
B- INFORMATION SECURITY
Bilgi, Uğur Teneke Ambalaj ve Plastik San. It is one of the most important assets of A.Ş. Uğur Teneke Ambalaj ve Plastik San. All kinds of information belonging to A.Ş. are confidential and the transfer and trading of this information to third parties is prohibited. Obligations regarding confidentiality continue after the termination of the current employment contract with the company.
this is trueAccordingly, it is the common responsibility of all employees to use information effectively, share it correctly and ensure the confidentiality, integrity and accessibility of information in this process. It is important that the management system established and the processes implemented in our company for the management and confidentiality of information are in harmony with each other in order to obtain the highest level of benefit.
Application basics
• Confidential Information includes, but is not limited to, business strategies, information regarding strategic partnerships and partners, financial information, trade secrets, customer-employee information, information regarding suppliers and all information, materials, programs and documents compiled during the working period, computer and telecommunication systems. , software, hardware and all other regulations and applications, as well as all works and agreements made by employees during their working time in the company, etc. It includes information.
• It is strictly forbidden to use such documents, information or tools for personal and private interests or for the benefit of third parties, institutions and organizations, during or after the working period, except where permitted and required by the duty in the company.
• Confidential files cannot be taken out of the institution. For confidential information that needs to be taken out of the institution, approval must be obtained from the person responsible for the information or the senior management.
• Passwords, user codes and similar identifying information used to access company information are kept confidential and are not disclosed to anyone other than authorized users.
• Company confidential information is not discussed in dining halls, cafeterias, elevators, service cars and similar public places.
• If information is to be shared with third parties and/or organizations, a confidentiality agreement is first signed for information sharing.
• Wage information is personal information, and the employee is prohibited from sharing his/her wages, fringe benefits and similar personal rights with other employees, or from trying to learn the wages, fringe benefits and personal rights of other employees, or from taking any action against the principle of wage confidentiality.
• Our employees who hold managerial positions have the right to see their own wages as well as the wages, benefits and similar personal rights of only the staff reporting to them. However, they are prohibited from sharing this information with any other manager or employee without permission from the management.
2. OUR RESPONSIBILITIES TOWARDS OUR EMPLOYEES
A- FAIR WORKING ENVIRONMENT
Uğur Teneke Ambalaj ve Plastik San. Inc. It considers creating and maintaining a fair working environment for employees as one of its most important priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment that is compatible with all relevant laws and regulations.
Application basics
• Company; Complies with all applicable laws and regulations regarding personnel policies, employment and working life.
• Recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. language, religion, race, sect, origin, gender, personal preference, physical disability, etc. in the processes. The professional abilities and competencies of the candidates for the relevant position are taken as basis, regardless of their differences, and other factors are not allowed to affect the decision.
• All employees have equal rights and opportunities in matters such as training, performance evaluation, social rights, worker health and occupational safety, which will reveal the potential of employees and/or ensure capacity development.
• Discrimination among employees within the institution due to language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons is unacceptable.
• A harmonious working environment that supports cooperation is created in the company, conflict environments are prevented, and people with different beliefs, thoughts and opinions are ensured to work harmoniously.
• Employees' private lives and personal spaces are respected.
• Personnel personal information is not used for purposes other than its intended purpose and is not shared with third parties without their consent.
• Violating the immunities of employees in any way, through physical, sexual, emotional and/or psychological (Mobbing) harassment, at the workplace or anywhere they are for work purposes, is against the law and ethical rules, and this crime is not tolerated by the Company in any way.
• No employee can demand privileged treatment, show privilege to anyone or be subject to a special treatment due to different gender, race, language or religion.
• Care is taken to employ a number of employees appropriate to the workload, to organize employees to achieve the highest efficiency during working hours, not to go outside working hours unless necessary, and to respect employee rights in cases requiring overtime. Employees are provided with regular annual leave.
• It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.
• Our company; Work safetyattaches great importance to training at all levels, especially on environment, waste management, energy efficiency, food safety and quality management, and organizes various trainings in order to prepare its employees for the future, ensure their personal development and increase their awareness levels.
• Confidentiality of employees and their reports who report situations contrary to the principles or in accordance with the complaint procedure is essential. Those who report will not be subjected to any persecution, discrimination, or unfair treatment due to their reports.
• Our company follows an "open door" policy and employees are expected to resolve their problems directly with their managers.
B- HEALTH, SAFETY AND ENVIRONMENT
Uğur Teneke Ambalaj ve Plastik San. Inc.; It has the management system audited by third party organizations in order to implement and develop the necessary management systems regarding Environmental and Occupational Health and Safety. All employees are expected to provide the necessary support to improve the system.
Application basics
a) Environment
• To support national and international environmental standards by complying with our environmental policies.
• Supporting all local environmental initiatives such as minimizing the negative impact of our travels, reducing water and energy consumption and recycling.
• Trying to change unsustainable behaviors that we and our team exhibit. To encourage working in an environmentally sustainable way and to provide the necessary support in this field.
• Working to achieve the company's environmental goals as well as its business goals.
• Where possible, evaluate in advance the environmental impacts of all business decisions for which we are responsible.
• Working with our suppliers and business partners to ensure that our business activities reflect our environmental awareness.
b) Occupational Health and Safety (OHS)
• To support national and international OHS standards by complying with OHS policies, procedures and instructions.
• To comply with the legal regulations regarding OHS.
• Participating in specified OHS basic training and internalizing and implementing OHS requirements.
• Predicting risks related to work and making suggestions for risk improvements. To take part in the actions to be taken.
3. OUR LEGAL RESPONSIBILITIES
• All our current activities and transactions are carried out by T.R. We comply with the laws and the basic principles of the Constitution and provide accurate, complete and understandable information to legal regulatory institutions and organizations in a timely manner.
• While carrying out all our activities and transactions, we remain at equal distance to all kinds of public institutions and organizations, administrative formations, non-governmental organizations and political parties, without any expectation of benefit, and we fulfill our obligations with this awareness of responsibility.
4. OUR RESPONSIBILITIES TOWARDS OUR PARTNERS
By giving priority to business continuity and in line with the aim of creating value for our partners; We avoid taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability, and manage our company's resources and assets and our working time with efficiency and savings awareness. We take care to increase our competitiveness and invest in areas that have growth potential and will provide the highest return to the connected resource. To our partners; We provide timely, accurate, complete and understandable information about our financial statements, strategies, investments and risk profile.
COMPANIES AND BUSINESS PARTNERS FROM WHICH GOODS AND SERVICES ARE PURCHASED AND SOLD
Companies and business partners from which goods and services are purchased and sold are required to comply with the Policy principles and other relevant legal regulations, and work with individuals and organizations that do not comply with these will be terminated.
a) Selection of Companies and Business Partners
During the selection of companies and business partners from which goods and services are purchased and sold, senior management takes into account criteria such as experience, financial performance, technical competence, as well as whether they act in accordance with ethical principles and legal requirements and whether they have a positive history in this field. We do not work with companies or business partners that have negative intelligence regarding bribery or corruption, even if they meet other criteria. In this context, the responsibility of conducting the necessary research and evaluations before entering into any business relationship lies with the senior management.
5. RESPONSIBILITIES OF EMPLOYEES
Relevant policies and procedures, as well as "ethical principles" regarding how we should behave and do our job, have been determined in detail. Compliance with these rules is the primary responsibility of all employees. In this regard, all employees;
• Performing his duties completely and without delay, under all circumstances, within the framework of the applicable legislation, company regulations and circulars, and the instructions given by his superior,
• Reading the Code of Business Ethics, knowing, understanding, internalizing and acting in accordance with the rules, principles and values contained therein,
• General and specific policies applicable to the company and its business. learning e procedures,
• Consult your manager and human resources regarding potential violations regarding yourself or others,
• Immediately report possible violations of oneself or others; You can make your notifications on these issues, either named or anonymously, by e-mail to info@ugurteneke.com.tr (notifications regarding violations of ethical principles sent to the e-mail address info@ugurteneke.com.tr will be directed to the Human Resources department), or by personally going to the human resources unit, to department managers or communicating through union representatives,
• There is a responsibility to follow the "Business Ethics Principles" defined to help act in accordance with the rules and solve problems.
6. RESPONSIBILITIES OF MANAGERS
In addition to setting an example by fully complying with the Business Ethics Principles and the values, principles and policies determined by the company, all managers;
• Ensuring that other employees are aware of the Ethical Principles or other relevant rules and procedures,
• Uğur Teneke Ambalaj ve Plastik San. Inc. To work to establish the corporate culture and to ensure that employees adopt the norms, values and principles that they must comply with. To organize periodic trainings and meetings in this direction,
• To create an environment where employees will not hesitate to bring their suggestions and all kinds of thoughts to them, as well as problems related to their work, and where they can communicate openly,
• Always act fairly and consistently in their behavior and decisions,
• Responsible for establishing a work environment where issues within the ethical principles can be discussed, and for fully implementing the procedures determined for all employee complaints and notifications.
7. RESPONSIBILITIES OF THE HUMAN RESOURCES DEPARTMENT
• Providing training at certain periods in order to inform employees about the principles of Business Ethics, ensuring the understanding of policies and rules, and ensuring continuous communication of this issue with employees,
• Those who are employed in the company are required to read the ethical principles, sign the Business Ethics Principles Commitment and be informed about this issue,
• Ensuring that notifications regarding violations of ethical principles submitted to it are discussed in the disciplinary board,
• To guarantee the confidentiality of complaints and notifications made within the framework of the Code of Business Ethics and to protect individuals after their notifications,
• To ensure the occupational safety of employees who notify,
• To ensure that complaints and notifications are investigated in a timely, fair, consistent and sensitive manner and to take necessary actions decisively as a result of violations,
• Responsible for ensuring that there is no discrimination on the basis of issues such as gender, disability, family status, sexual orientation, age, political and philosophical opinions, race, religious beliefs, union activities, education, promotion, employment and working conditions in general.
8. POLICY VIOLATIONS
A. BE CAREFUL WHEN MAKING ETHICAL DECISIONS!
Application of the principles If any questions arise regarding the principles, be sure to make a plan of action. Following the steps below and asking yourself these questions as a guide in deciding on an action plan will ensure that the system works much more healthily. If you think it is necessary, consult the Human Resources Department.
a) Identifying the Event, Decision or Problem
• Have you been asked to do something that you think might be wrong?
• Uğur Teneke Ambalaj ve Plastik San. Inc. Are you aware of a potentially illegal or unethical situation within your organization or with your customers?
• Are you trying to make a decision and have doubts about how you should act in accordance with business ethics?
b) Think Before You Decide
• Try to clearly define and summarize the problem or question
• Ask yourself why there is a contradiction.
• Consider the options and their consequences
• Consider who might be affected
c) Decide on a Plan of Action
• Determine your responsibilities
• Review all relevant facts and information
• Uğur Teneke Ambalaj ve Plastik San. Inc. Consult policies, procedures and guidelines
• Assess risks and think about how you can reduce them
• Try to create the best plan of action
d) Test Your Decision
• Review the questions that need to be asked from an ethical perspective
• Review your decisions within the framework of the company's core values
• Be sure to consider company policies, laws and professional standards.
• Consult with qualification holders and consider their views within your planned course of action.
e) Continue With Determination
• Share your decision with the relevant people, along with your justifications
• Share what you've learned
• Share your success story with others
f) 4 Basic Questions to Consider
1. Does this activity/behavior comply with the law, rules and traditions?
2. Is this activity/behavior balanced and fair? Would we be bothered if someone else did it?
3. Another form of behavior that cannot create an ethical conflictis there?
4. Who may be affected by this activity/behavior? Will there be any negative repercussions for you or our company?
B. RESOLUTION OF NONCOMPATIBILITIES WITH BUSINESS ETHICS PRINCIPLES
Those who violate the Code of Business Ethics or Company policies and procedures will be subject to various disciplinary sanctions, up to and including being asked to leave the job, if necessary.
Disciplinary sanctions will also be applied to those who approve or direct inappropriate behavior and actions that cause violation of the rules, or those who have knowledge of these issues and do not make the necessary notification appropriately.
a) Board
Investigation and resolution of complaints and notifications regarding violations of the Ethical Principles are carried out by the disciplinary board. The Disciplinary Board keeps the identity of those who make a notification or complaint confidential and conducts the investigation within as confidential rules as possible.
C. CONTACT
The following e-mail and postal addresses can be used for your questions and notifications.
Email: info@ugurteneke.com.tr
Posta Uğur Teneke Ambalaj ve Plastik San. Inc. Attention to Human Resources Department
DOSB 2nd Section D-2006 St. No:4 41455 Dilovası / KOCAELİ
Phone: 0 262 754 01 10