Code of Ethical Conduct

The code of ethical conduct all employees of İlbak Holding and its affiliated companies are expected to follow includes, but is not limited to, the following principles:

• Always abide by laws and regulations.
• Carry out duties in a manner that aligns with basic moral values.
• Create shared value in all dealings, through fair, well-intentioned and considerate behavior.
• Abstain from any ill-gotten gains in dealings with individuals and corporations for any reason whatsoever, and to never give or take bribes.
• Abide by relevant ethical rules and their corresponding implementation guidelines in carrying out all tasks.
• Never take any action, produce any written document or make any announcement that could put the Company in an awkward position or commitment.
• Avoid any behavior that could disturb and/or damage fellow associates and avoid disrupting workplace harmony.
• Pay utmost attention to the Company's material and immaterial assets, data and information systems, treating them as if they were one's own property; protect such assets against possible damage, loss, misuse, abuse, theft and sabotage.
• Never make direct or indirect use of work time and Company resources for private and/or political activities and interests.

Asset and Information Management
 

Intellectual Property Rights

• Ensure that all due legal procedures are initiated and completed in a timely fashion for the protection of the intellectual property rights regarding any product, process or software devised by the Company
• Avoid the deliberate, unauthorized use of other companies' patents, copyrights, commercial secrets, brands, computer programs and other intellectual or industrial property

Information Management

• Ensure that all legal records are kept in the proper manner.
• Refrain from responding to third party demands concerning confidential Company data, without the prior consent of senior management.
• Take great care to ensure the accuracy of the Company's announcements and reports.

Safety and Crisis Management

• Take the necessary precautions for the protection of Company employees, information and data systems, operation areas and administrative buildings against possible terrorist attacks, natural hazards and malevolent actions.
• Undertake the necessary crisis management planning in cases of terror, natural hazards, etc., to ensure the continuity of the business with minimal loss during such a crisis.
• Take all necessary measures to avoid theft or damage of Company assets.

Confidentiality

• Act to protect and safeguard the confidentiality of İlbak Holding's and affiliated companies' financial and commercial secrets, any data that could damage their competitiveness, personnel rights and related data, and contracts with business partners.
• Never share business-related information and relevant documents with unauthorized individuals and parties inside or outside the Company for any purpose whatsoever, and never make direct or indirect speculative use of such material.
• Refrain from using any confidential information concerning İlbak Holding and affiliated companies, their customers and other individuals and companies that İlbak Holding and its affiliates deal with outside of its specified purpose, or from sharing this with third parties without obtaining the required permission.

Avoidance of Conflicts of Interest

A conflict of interest is a situation in which employees have a private interest concerning a material or other kind of benefit to themselves, their relatives, friends or contacts that affects or could affect their ability to carry out their duty in an impartial manner.

Avoidance of Transactions to Benefit Oneself or One's Relatives

• Avoid generating ill-gotten gains for oneself, relatives or third parties, by making use of professional status or authorization.
• Ensure that personal investments do not result in conflict of interest with the Company.
• Take care that no personal investment or non-professional activity interferes with the time and attention needed to effectively execute ongoing duties at İlbak Holding and/or its affiliated companies, and avoid circumstances that prevent concentration on one's responsibilities.
• Inform the relevant Board Member if one becomes engaged in a transaction with a first degree relative who is an authorized, decision making officer in a customer or supplier company.
• Reveal shares or participation in another company before employment commences. Candidates are specifically asked to provide such information in job interviews. Employees must report any relevant changes regarding activities with other companies or similar issues that could result in conflicts of interest to their immediate superiors, and this information will be shared with officials at least two levels in the hierarchy above the employee concerned.
• Inform one's immediate superior if one learns of any relatives that have obtained shares or materially benefitted from a company with which İlbak Holding and/or its affiliates have commercial dealings.

Representation and Participation in Gatherings

• Obtain prior approval from the relevant Board Member before participating in any sports activities, domestic or foreign trips and similar gatherings that might affect or be seen to affect decision-making procedures organized by individuals or institutions with which the Company has or might eventually have business dealings. This excludes open conferences, receptions, promotional activities, seminars and similar public events.

Receiving and Giving Gifts

Employees must abide by the following principles in any dealings with private or public individuals or establishments that wish to establish or maintain professional relations with İlbak Holding and/or its affiliates:

• Decline to accept or proffer any gift that might convey the appearance of irregularity or result in or be perceived as resulting in a dependent relationship. Gifts, souvenirs and promotional material deemed as belonging to commercial customs and traditions are exceptions.
• Decline to request or accept any discount or benefit that might seem inappropriate from suppliers, customers, İlbak Holding and/or its affiliated companies or third parties.

Former Employees' Professional Dealings with İlbak Holding and/or its Affiliated Companies

Cases in which a former employee of the Company establishes a company or becomes a partner in a company that establishes a relationship with İlbak Holdings and/or its affiliates as a supplier, contractor, consultant, commissioner, representative, dealer, etc., are critical and delicate and might lead to undesirable perceptions.

Any action taken before or after such an occurrence must protect the interests of the Group, abide by moral or ethical standards and avoid conflicts of interest.

When a former employee becomes a supplier, the concerned executive should contact the affiliate within the Company in which the supplier previously worked, prepare a report demonstrating the absence of any inappropriate dealings and communicate this information to her/his immediate superior.

If an inappropriate situation does arise, no commercial relationship should be established with the person in question.

Except in cases in which a Board Member issues the requisite approval, such commercial dealings should not be approved until two years after the former employee has left the company.

Insider Trading

Know that it is legally a crime to use any confidential information about İlbak Holding or its affiliated companies to pursue any commercial benefit, including direct or indirect purchases of shares from stock exchanges, or to deliver such information to third parties (namely, insider trading) in an effort to benefit. Never take such actions.