The objective of SC Egitim Araclari LTD. Anti-Corruption Policy is to clarify the approach of the Group in the combat against bribery and corruption and to ensure compliance with the SC Egitim Araclari LTD. Code of Ethical Conduct and the Ethics Board Guidelines and applications. ▪ With this policy, it is intended to manage these risks through compliance with legal regulations and ethical principles, and the identification of bribery and corruption risks. ▪ Anti-Bribery and Anti-Corruption Policy; f. SC Egitim Araclari LTD. Board of Directors Members g. SC Egitim Araclari LTD. company executives and employees, h. Subsidiaries, affiliates and their employees, i. Companies and business partners for outsourced services and their employees j. It includes customers, subcontractors and all other parties involved in the business.
Corruption is the mistreatment of a duty or authority held due to the position of the person with the purpose to gain direct or indirect profit. Actions of corruption include any acts of providing or offering, promising, receiving, accepting, requesting or soliciting money, gifts, money or any other interest either measurable or non-measurable with monetary values in order to gain or maintain interest during professional activities. ▪ Bribery means gaining profits within the framework of a verbal or written agreement to act contrary to the requirements of a person's duty by means such as performance, nonperformance of, speeding-up or slowing down in conducting the professional activities.
3.1. Board of Directors The Board of Directors shall be responsible for the implementation of the policy and for the executive supervision of conducting of all stages together with the reporting, review and sanction mechanisms, in the case the rules and regulations are not complied with.
3.2. SC Egitim Araclari LTD. Employees All SC Egitim Araclari LTD. employees are obligated to comply with the principles set out in this policy text. The managers should ensure that the principles stated under this policy are understood and applied by their managed employees. The employees cannot be forced to act against this policy by anyone in any circumstances. When any behavior, activity or practice contrary to the Policy is encountered, this will forthwith be reported to the SC Egitim Araclari LTD. Ethics Board. The rejection of SC Egitim Araclari LTD. employees to bribe in any way or to report against corruption shall not constitute any contradiction to this Policy.
3.3. SC Egitim Araclari LTD. Ethics Board The Secretary of the Ethics Board works under the Anel Holding Vice Chairman of the Board of Director, who is the Chairman of the Ethics Board and is responsible for the following issues within the scope of this Policy:
The development, identification and publication of an effective anti-bribery and anticorruption program and the conduct of this Policy in this context, ▪ Adoption of the Policy rules, making updates in accordance with all relevant legal and regulatory requirements and organizing activities for the proper and correct implementation of the Policy, ▪ Providing opinion regarding anti-bribery and anti-corruption; ▪ Ensuring the establishment of communication channels required for reporting complaints and serving notifications for the violation of the Policy, taking measures to ensure the confidentiality and security of the reporting and notifying persons, ▪ Conducting the investigation and interrogation regarding the complaints, notices or allegations received related to the contradiction to the policy and determining the sanction to be applied accordingly. The SC Egitim Araclari LTD. Ethics Consultancy and Information e-mail address is utilized for consulting and informing the Anel employees and the SC Egitim Araclari LTD. employees close to them regarding their behavior under the "Code of Ethical Conduct and the Ethics Board Guidelines". In this context, it is expected that all information exchange to be made within the scope of this Policy is made over the below mentioned e-mail address.
E-mail address: etik@scegitimaraclari.com
3.4. Human Resources Directorate Human Resources Directorate will be responsible for taking the necessary measures and providing the required information during the human resources processes (employment, communication, training, etc.) in order to comply with the policy
3.5. Companies and Business Partners Providing Outsourced Services Companies, suppliers, subcontractors, customers and all other parties providing outsourced service, including support services and professionally affiliated with the with SC Egitim Araclari LTD. are informed about the principles of the Policy. It is obligatory that all persons and institutions who have been informed comply with the Policy and other relevant regulations.
4.1. Bribery and Corruption The SC Egitim Araclari LTD. strictly rejects bribery and corruption pursuant to its policies and corporate ethical procedures and undertakes to maintain all its activities in a fair, transparent, integral and legal manner in accordance with ethics. In this respect, proposal, receipt, granting and even implication of bribery is unacceptable. This Anti-Bribery and Anti-Corruption Policy has been put into effect as per the necessity arising as the result of the sensitivity regarding this issue. In order to ensure that this Policy is implemented in efficiently and correctly the following will be conducted by the SC Egitim Araclari LTD.: ▪ In order to ensure effective combat against bribery and corruption, possible risks will be determined by the related departments of the SC Egitim Araclari LTD. and necessary measures will be taken related to these risks. ▪ Necessary trainings and awareness programs are provided for the employees and business partners on the legal requirements for the anti-bribery and anti-corruption program. Secure and accessible communication channels are provided to enable the employees to report suspicious situations.
SC Egitim Araclari LTD. business ethics approach, SC Egitim Araclari LTD. Code of Ethical Conduct and the Ethics Board Guidelines have been put into written form both in Turkish and English and are published together with this Policy and on the internet site and intra-group intranet channel. ▪ Within the scope of the audit activities carried out within SC Egitim Araclari LTD., auditing activities are also carried out against the risks of bribery and corruption. Bribery and corruption can take place in many different ways, including: f. Gifts, g. Political or other donations, h. Facilitation Payments, i. Representation and entertainment j. Other benefits, etc.
4.2. Gifts and Donations A gift may be expressed as a product that does not require a financial payment and is generally given by persons with whom professional relation is retained or customers as a commercial courtesy or to express gratitude. ▪ All gifts given to third parties by SC Egitim Araclari LTD. are offered publicly and in in good faith. For the acceptance of the gifts, the same conditions shall apply and symbolic gifts given to the company not having higher material values will be accepted, excluding the ones intended to be given to the personnel individually.
SC Egitim Araclari LTD. employees may not accept or offer any gifts that would damage their independent relations with government employees, subcontractors, suppliers, customers and other business partners. ▪ Due care is shown to avoid situations that may lead to conflict of interest or that may be perceived as so and not to offer or accept gifts in such cases. SC Egitim Araclari LTD. has taken the principle not to adopt any political views, provide material, moral support or support in kind to political institutions or persons and not to give any commitments. In this context; ▪ It constitutes basis that no institutional or personal payment is effected, no gift, aid and donation is granted for a decision to be affected at the stage of receiving and providing service related to sustaining the SC Egitim Araclari LTD. activities or which may be in favor of the SC Egitim Araclari LTD. to any governmental authority or political party candidate or directly to a political party, to any group or institution affiliated with politics. ▪ The contributions and sponsorships with aid purposes done by the SC Egitim Araclari LTD. must be legal, in compliance with company rules, policies, guidelines and regulations and furthermore in accordance with the applicable local laws.
4.3. Facilitation Payment No payment shall be accepted and effected for the assurance, facilitation and acceleration of any business by the SC Egitim Araclari LTD.. Employees of the SC Egitim Araclari LTD. will not tolerate any offer, promise, solicitation, grant or acceptance by the counter party in its relationship with third parties.
4.4. Contracts and Tenders
The SC Egitim Araclari LTD. takes due care to comply with this Policy in the contracts it is a party to and in public or non-public tenders in the case a business relationship is initiated or sustained. In this context, prior to the establishment of any business partnership or appointment of any agents, including mergers and acquisitions, the counter party in question will be subject assessment in terms of bribery, corruption risks and business ethics. It is imperative that the persons acting on behalf of SC Egitim Araclari LTD. by establishing a professional relation, the suppliers, subcontractors and other persons and institutions with such relation agree to comply with the legal regulations and our anti-bribery and anti-corruption policy in force. 4.5. Representation and Entertainment Entertainment may be offered by SC Egitim Araclari LTD. to third parties to develop commercial relationships and to establish normal commercial communication networks. Among these third parties, customers, suppliers, subcontractors, consultants and other companies with commercial relationships with SC Egitim Araclari LTD. could be included. The entertainment offered by the SC Egitim Araclari LTD. is done so unconditionally and on a goodwill basis and due care is shown to ensure that the representation and entertainment activities are to a certain extend.
The Anti-Bribery and Anti-Corruption Policy has been announced to SC Egitim Araclari LTD. employees and is continuously and easily accessible in the web site of SC Egitim Araclari LTD. and intranet environment. Trainings are organized for the employees to adopt the principles contained in this policy and to continue to work in accordance with these principles.
The matters to be complied with regarding the accounting system of the companies within SC Egitim Araclari LTD. have been defined within the framework of the related legislation and regulations. Pursuant to this, due care is shown by SC Egitim Araclari LTD.; ▪ to record and keep all accounts, invoices and documents belonging to third parties (customers, subcontractors, suppliers, business partners and other service providers, etc.) in a reliable, complete, transparent, fair and correct manner, ▪ to establish their own internal control systems to prevent unregistered transactions, ▪ not to falsify any accounting or similar commercial records related to any transactions and the facts are not diverted
In the case the Anti-Bribery and Anti-Corruption Policy is breached, disciplinary penalties which may lead to the termination of the employment contract based on the nature of the incident may be in question. The situations contrary to this Policy will be reviewed by the Ethics Board and the necessary sanctions will be applied in the case any irregularities are detected.
