İlbak Holding Corporate Ethics and Compliance Policy Documents
İLBAK HOLDING
İLBAK HOLDING CORPORATE ETHICS AND COMPLIANCE POLICY DOCUMENTS
A. Purpose and Commitment
İlbak Holding and all its affiliates, subsidiaries, and partners (“Holding”) undertake to conduct all their activities in accordance with the principles of integrity, transparency, and accountability. Within the scope of these Corporate Ethics and Compliance Procedure Manuals and Documents, the Holding aims to establish ethical standards of conduct across the organization, ensure adherence to compliance procedures, prevent bribery and corruption risks, and ensure compliance with the laws of the Republic of Türkiye and applicable international legislation.
B. Legal Basis and Compliance Framework
National Legislation:
These Corporate Ethics and Compliance Procedure Manuals and Documents have been prepared based on all applicable local legislation, primarily including Labor Law No. 4857, Turkish Penal Code No. 5237, Turkish Code of Obligations No. 6098, Law No. 3628 on Declaration of Assets and Combating Bribery and Corruption, Law No. 6698 on the Protection of Personal Data (KVKK), and Law No. 4054 on the Protection of Competition.
International Standards:
As part of global trade, Holding adopts compliance with the following regulations:
- FCPA & UKBA: United States and United Kingdom Anti-Bribery Laws.
- OFSI: Office of Financial Sanctions Implementation and NCAs, CFSP.
- OFAC: U.S. Department of the Treasury Office of Foreign Assets Control sanctions regimes.
- ISO 37001 & 37301: Anti-Bribery and Compliance Management System standards.
I.ILBAK HOLDING CODE OF ETHICAL CONDUCT AND IMPLEMENTATION PRINCIPLES
A. CODE OF ETHICAL CONDUCT
1. PURPOSE AND SCOPE
1.1. Purpose
This Policy has been established to ensure that İlbak Holding and its affiliates (“Holding”) conduct their commercial activities in accordance with the principles of integrity, transparency, and compliance with the law, to minimize corruption risks, and to make global compliance standards an integral part of the corporate culture.
1.2. Scope
The provisions of this Code of Ethical Conduct are binding upon all employees of the Holding, members of the Board of Directors, senior executives, and all third parties acting on behalf of the Holding (including suppliers, subcontractors, consultants, agents, and business partners).
2. CORPORATE VALUES AND LEADERSHIP COMMITMENT
İlbak Holding considers reliability and reputation as its most fundamental assets in every sector in which it operates. Acting fairly, in good faith, and with understanding in order to fulfill duties within the framework of fundamental moral and human values and to ensure mutual benefit in all relationships constitutes the Holding’s core principle. Our managers are not only supervisors of these rules but also their direct implementers and role models. They are tasked with fostering an environment, through an “Open Door” policy, in which ethical concerns can be expressed without fear. Furthermore, every employee of İlbak Holding undertakes to accept these policies, procedures, and rules as a guiding compass in their daily decisions.
3. WORKING PRINCIPLES AND HUMAN RIGHTS
İlbak Holding guarantees a working environment consistent with human dignity to all its affiliates, employees, and partners.
3.1. Equal Opportunity:
Only competence, performance, and merit shall be taken as the basis in recruitment, promotion, training, rotation, and compensation processes. No discrimination based on religion, language, race, gender, age, or disability is tolerated within İlbak Holding, and such discrimination is strictly prohibited.
3.2. Anti-Harassment and Anti-Mobbing:
A “Zero Tolerance” policy applies against psychological harassment, sexual harassment, or any form of bullying in the workplace. It is essential to refrain from any behavior that may disturb or harm other employees and to maintain workplace harmony. A safe and peaceful working environment is a fundamental right of every employee.
3.3. Child Labor and Forced Labor:
İlbak Holding adopts a strict stance against child labor and forced labor in its operations and supply chain. İlbak Holding does not tolerate child labor or forced labor either in its own operations or in the processes of its business partners.
4. INTEGRITY AND STAKEHOLDER RELATIONS
Unless expressly authorized, no action, statement, or correspondence that may bind the company may be undertaken. Full compliance with competition law rules shall be ensured; no unfounded statements shall be made regarding competitors, and no actions contrary to unfair competition legislation shall be taken. It is essential to refrain from behavior that may disturb or harm other employees and to maintain workplace harmony. Objective criteria (price, quality, ethical compliance) are applied in all stakeholder selections, including suppliers, sponsors, and business partnerships. Business partners are expected to fully comply with İlbak Holding’s ethical rules. İlbak Holding adopts an honest, transparent, and professional approach towards its customers in all sectors in which it operates. Full compliance with competition law rules is ensured in all sectors (including advertising, mining, etc.). No information regarding competitors is obtained through unethical means, no unfounded statements are made, and no actions contrary to unfair competition legislation and principles are undertaken.
5. PROTECTION OF ASSETS AND INFORMATION
Employees are obliged to treat all tangible and intangible assets of the company with the same care as their own property and to protect them against possible loss, damage, misuse, abuse, theft, and sabotage.
5.1. Confidential Information and Trade Secrets:
Mining site data, advertising strategies, customer lists, financial projections, monitoring data, broadcasting data, and all financial and corporate data relating to stakeholders, partners, affiliates, and subsidiaries of İlbak Holding, without limitation, are considered “Insider Information” and may not be shared with third parties. Information obtained in the course of work may not be disclosed to unauthorized persons or authorities for any purpose whatsoever.
5.2. Insider Trading:
Using or disclosing any confidential company information to conduct direct or indirect trading of shares on stock exchanges constitutes a criminal offense and is strictly prohibited.
5.3. Intellectual Property Rights:
All software, reports, content, publications, visuals, programs, channel data, and campaign ideas produced within the Holding are the property of İlbak Holding. Unauthorized use of patents, trademarks, and copyrights belonging to other entities is strictly avoided.
5.4. Use of IT Resources:
Computers, email systems, and internet access shall be used solely for business purposes. The transmission of illegal or unethical content through company systems is prohibited.
5.5. Information Management and Data Privacy (KVKK):
Within the framework of the Law on the Protection of Personal Data and the GDPR, all personal data of employees and stakeholders are stored with the highest level of security. Employees must ensure that all legal records are properly maintained and that submitted reports are accurate. Requests for confidential information from third parties may not be answered without the approval of senior management.
6. ETHICAL RELATIONS BETWEEN EMPLOYEES AND THIRD PARTIES
Employees undertake not to obtain any unjust gain from any person or entity, and not to give or receive bribes under any circumstances. Unless expressly authorized, employees may not engage in any conduct, statement, or correspondence that may bind the company. Employees are obliged not to use working hours and company resources, directly or indirectly, for personal interests and/or political activities.
6.1. Professional Distance and Objectivity:
Employees shall maintain appropriate professional distance in their relationships with suppliers and business partners and shall avoid personal relationships that may influence decision-making processes.
6.2. Fair Treatment:
Equal opportunity shall be provided to all supplier and business partner candidates. Selection processes shall be conducted objectively based on merit, quality, price, and ethical compliance criteria.
6.3. Respect Towards Stakeholders:
Employees are obliged to demonstrate the same level of respect and professionalism to third-party employees (such as security, catering staff, subcontractors, etc.) working on behalf of İlbak Holding as they do to their own colleagues.
6.4. Professional Relations Among Employees:
All employees of İlbak Holding, including those working in affiliates and subsidiaries, are obliged to treat each other with respect and professionalism.
7. BUSINESS ETHICS AND CODE OF CONDUCT
7.1. Confidentiality of Information:
Stakeholders must keep confidential, for an indefinite period, all trade secrets, projects, and data of İlbak Holding learned within the scope of business relationships (under NDA).
7.2. Protection of Reputation:
Stakeholders may not make any unfounded or defamatory statements that may harm the reputation of İlbak Holding on any platform, including social media.
7.3. Prohibition of Conflict of Interest:
Suppliers and third parties with potential business relationships may not offer employees of İlbak Holding or their relatives any business opportunities, partnerships, improper discounts, opportunities, or gifts that would create a benefit.
8. PROTECTION OF COMPANY INFORMATION AND INFORMATION SYSTEMS
Employees are obliged to exercise due care over all tangible and intangible company assets as if they were their own property and to protect them against loss, damage, misuse, abuse, theft, and sabotage.
8.1. Protection of Intellectual Property Rights:
Employees are obliged to ensure that legal procedures are initiated and completed in a timely manner to secure intellectual property rights for newly developed products, processes, software, and works. They must avoid and refrain from knowingly unauthorized use or infringement of patents, trademarks, copyrights, trade secrets, software, and all other intellectual and industrial property rights belonging to third parties. Any copyright infringement or potential infringement must be reported immediately to the Legal and Compliance Department.
8.2. Information Management:
Employees are obliged to ensure that all legal records are properly maintained. They may not respond to requests from third parties for information classified as confidential without the approval of senior management. Employees must exercise due diligence to ensure that all statements disclosed, and reports submitted by Holding are accurate.
9. SECURITY AND CRISIS MANAGEMENT
Necessary measures shall be taken by relevant personnel to protect information systems, factories, and operational systems against potential threats such as terrorism, natural disasters, malicious acts, cyber-attacks, and other force majeure events. Emergency crisis planning and management aimed at ensuring business continuity with minimal loss during crises are essential. All cyber security incidents, including attacks and hacking attempts, must be immediately reported to relevant managers and the Legal and Compliance Department. Employees shall take all necessary measures to prevent theft or damage to company assets.
10. CONFLICT OF INTEREST AND ETHICAL RELATIONSHIP RULES
10.1. Conflict of Interest:
A conflict of interest refers to any benefit provided to employees, their relatives, or related people that affects their ability to perform their duties impartially. Any situation where the corporate authority and responsibilities of an employee or manager conflict with their own personal, financial, or political interests or those of their family or close associates shall be deemed a conflict of interest.
10.2. Prohibition of Acting for Personal or Relatives’ Benefit:
No unjust benefit may be obtained for oneself or relatives by using title or authority. Working hours and company resources may not be used, directly or indirectly, for personal interests or political activities.
10.3. Shareholding in Another Company:
Employees are obliged to declare to the Human Resources Department, upon hiring, any shareholding in another company, ownership of a company, or any position held on a board of directors or in management.