1. PURPOSE.

The purpose of this procedure is to define the approach and Ethical Principles of Tunaset to meet the requirements arising from all legal regulations and contracts, and to provide a formal disciplinary process for personnel who deliberately attempt to violate ethical principles and security.

2. SCOPE AND RESPONSIBILITIES.

• This procedure has been prepared within the scope of ISO 37001;2016 Standard.
• This procedure was prepared by the Quality System Manager and approved by the General Manager.
• This procedure can be applied in all subsidiaries of Tunaset, such as offices, warehouses, etc., in line with the decisions to be taken by the Senior Management.
• General Manager, Customs Consultants, Customer Representatives, Accounting, Finance and Human Resources Officers, KÇG, BGÇG, ÇÇG, EÇG, IT Officer, Foreign Service Companies and Quality System Manager are responsible for the implementation of this procedure.

3. APPLICATION.

3.1.TUNASET ETHICAL PRINCIPLES.

The Ethical Principles Scope of Tunaset is as follows;

• Respect for the Customer
• Compliance with Laws and Legislation
• Supply chain ethics studies
• Information Security requirements
• Preventing the occurrence of irregularities, impropriety and misrepresentation
• Combating bribery and corruption
• Confidentiality and Protection of Personal Data
• Ensuring compliance with Environmental Management
• Ensuring compliance conditions with Occupational Health and Safety
• Compliance with human rights and Ethical employment policies
• Prevention of conflicts of interest
• Avoiding retaliation
• Fair Competition conditions
• Investor protection and win-win management
• corporate citizenship

3.2. CUSTOMER RELATIONS and PRINCIPLES.

One of the most important resources and assets of Tunaset is its customers. Evaluating, solving and analyzing the problems that occur and/or may occur within this framework and within the scope of the services it provides is an issue that all Tunaset employees should prioritize.

Customers' special requests and satisfaction should be prioritized, and all transactions should be carried out within the scope of Turkish Laws and Legislations.

Regulation and development of relations with customers are clearly defined in (KP.04) Customer Relationship Management and (KT.07) Job Descriptions, and these rules are applied without compromise.

The acts and risks of fraud are defined below.

The purpose and duty of Tunaset Management is to provide information to all its employees in order to identify, reduce and manage the risks of corruption by constantly adopting these policies. It is the duty of the Senior Management to take all measures and increase their effectiveness in the absence of accounts, funds, assets that cannot be disclosed or recorded for any purpose, and that such transactions should not be made.

In order to monitor these procedures and policies regularly, an Ethics Working Group (ECG) consisting of the General Manager and Customs Consultants has been established within Tunaset. The establishment of this working group (EPL.00.C) has been announced with the Establishment and Notification document. .00.D) document. In accordance with this document, ECD is responsible for the protection, supervision and follow-up of all Ethical Principles.

3.5.1. HUMAN RESOURCES.

The Human Resources department is responsible for recruitment, notification of the duties, authorities and responsibilities of the personnel, having them read and signed, and providing training on related issues.

Each of our employees, while performing their duties, must comply with this policy of Tunaset, relevant legal regulations and all applicable anti-corruption laws. The personnel must notify the ECD of all corruption acts that they are aware of or attempted, whether or not an act of corruption has been proposed, given or received. is responsible.

3.5.2. COMPANIES THAT PROVIDE FOREIGN SERVICE.

All rules that bind outsourced services and ethical approaches related to them (KP.05) are strictly applied in accordance with the Outsourced Services Management and sub-Instructions.

Firms and business partners from which outsourcing services, including support services, are required to comply with policy principles and other relevant regulations, and relations with individuals and organizations that do not comply with these are reviewed.

The senior management takes into account criteria such as experience, financial performance, technical competence, as well as morality and a positive background in this field, during the selection of outsourced companies and business partners. Relationships with companies that have negative intelligence about bribery or corruption are reviewed. In this context, the responsibility of carrying out the necessary research and evaluation primarily rests with the Senior Management.

In agreements and contracts to be made with companies and business partners that have positive intelligence and meet other criteria;

• Ensuring full compliance with the principles specified in the policy and other relevant regulations,
• Employees assimilate these principles and act accordingly,
• Ensuring that its employees receive training on policy periodically,

Conditions regarding regular reminders to its employees about their reporting obligations and encouraging them to report in case of such situations are included, provisions are made regarding termination of employment in case of non-compliance with these or a situation contrary to the policy.

It is primarily Tunaset Senior Management's responsibility to monitor the compliance of the firm or its business partners with the aforementioned issues.

3.5.3. REPRESENTATIVES and AGENTS.

Using Agents and Agents may pose one of the high risks that could lead to corrupt acts. This risk can only exist if an agent operates in a high-risk country.

Since an act of corruption committed by third parties can be deemed to have been committed by Tunaset, the use of an intermediary must comply with this policy and other procedures in this regard.

No intermediary should be hired without adequate and careful scrutiny to ensure that it will not tarnish Tunaset's reputation and that it meets the qualifications for the task it is intermediating with.

3.5.4. GIFTS

Our employees do not receive any goods/services exceeding 100 TL (One Hundred Turkish Lira) for any transaction or business, or cash, check, etc., regardless of its value. cannot demand, provide or accept benefits. Gifts or other gifts that may affect or aim to influence the preferences and decisions of our company should not be accepted, such requests should not be made.

Although the main rule is not to accept gifts within the scope of company policy, there is no harm in accepting gifts provided that the following conditions are observed:

If possible, the supervisor should be informed about this before or immediately after,

It is not done with the intention of influencing, encouraging or rewarding a third party in order to obtain any benefit through unfair performance or to provide each other with mutual advantages or benefits, express or implied,

Compliant with national legislation

3.5.5. ENTERTAINMENTS

Hospitality is an event or activity sponsored by an external person or company. Hospitality events/activities include:

• social events
• Accomodation
• dinner invitation

The Company may offer hospitality to third parties to improve its commercial relations and to establish a normal commercial communication network. These third parties include clients, consultants, lawyers, auditors and other related companies (including their employees, family and friends) with whom the companies have business relationships. The company offers its hospitality publicly, in good faith and unconditionally.

The same principle applies to the acceptance of hospitality offers on behalf of personal or related persons (family members, friends, close associates, etc.). When a high-value hospitality offer is received, which may not be in line with company principles, the approval of the unit manager must be obtained.

Even if it is in compliance with the issues specified in the policy, situations that may cause or be perceived as a conflict of interest should not be caused, and hospitality offers should not be offered or accepted in such cases.

3.5.6. FACILITATING PAYMENTS.

Tunaset does not allow individuals and organizations within the scope of this policy to offer facilitation payments to secure or speed up a routine transaction or process (obtaining permits and licenses, obtaining documents, etc.) with government agencies.

3.5.7. JOB OFFERS.

To remove the impression that a job offer (temporary or permanent) may in any way be an act of corruption, such offers are made available to customers, business partners (third parties known to be closely related to them), or government officials and public officials “outside of normal competitive recruitment processes”. or to persons known to be closely related to Government Officials) is the general principle.

3.5.8. COMPANIES WORKED BY ATTORNEY.

Tunaset, the person or suspected of giving bribes to third parties in relations with persons and/or institutions such as proxies, suppliers and contractors, who provide services as a proxy, provide management consultancy, deal with functions such as accounting, payroll, information technologies or facility management, or should not establish relations with institutions, if a relationship established as of the date of receipt of the aforementioned type of hearing, relevant warnings are made; If the warnings fail, the commercial relationship is terminated.

Persons, suppliers or contractors who establish a relationship with Tunaset and act on behalf of it must agree to comply with legal regulations and all applicable anti-corruption laws.

3.5.9. POLITICAL DONATIONS.

No political donations are made by Tunaset.

3.5.10. CHARITABLE DONATIONS and SPONSORSHIPS.

Tunaset, the charitable contributions and sponsorships to be requested must only be legal, in compliance with the regulations, policies, directives and regulations issued by Tunaset and also in accordance with the local laws in force.

All charitable contributions and sponsorships must be made in an open and transparent manner. In this case, transparent criteria should be established for the selection of buyers.

3.5.11. ANTI-CORRUPTION and ANTI-BRIBERY PRINCIPLES.

Tunaset has zero tolerance for acts of corruption. Any acts of corruption are not tolerated in the transactions of Tunaset employees and/or third parties with Tunaset.

While performing their duties, our employees cannot make a payment to a third party that can be considered as a bribe in any way, or if the other party offers or promises this in their relations with third parties.

It does not tolerate asking, demanding, giving or accepting anything.

All our employees are obliged to act in accordance with the rules regarding bribery and the Compliance and Ethical Rules published by the company.

3.5.12. NOTICE OF VIOLATIONS RELATED TO CORRUPTION AND BRIBERY.

In order to protect the reputation of our company, it is the individual responsibility of all our employees to report any violation of anti-corruption rules.

If any of our employees violate the rules in this policy, the Ethics Working Group is informed.

Failure to report or ignore cases contrary to acts of corruption, even though it is noticed, will also be considered as a violation of anti-corruption rules.

All of our employees should report questions about the anti-corruption policy and those who violate the rules set forth in this policy or suspicious situations that may harm our reputation and trust. The Incident Notification Form (BF.02.A) or [email protected] is used for the reporting and analysis of these situations. .

3.5.13. VIOLATION OF ANTI-CORRUPTION RULES AND ITS CONSEQUENCES.

Our managers and all our employees are obliged to comply with this policy, relevant legal regulations and all applicable anti-corruption laws while carrying out their jobs.

Not knowing the rules in this policy cannot be accepted as an excuse for violation.

In case of violation of this policy, disciplinary penalties may be brought up to the termination of the employment contract, depending on the nature of the incident.

In addition, those who do not comply with relevant legal regulations and all applicable anti-corruption laws may be subject to criminal liability.

In the contracts made with the companies from which outsourcing services are received, or with the persons and organizations working on behalf of the company, there are provisions stating that the works will be terminated if it is determined that there is behavior, attitude or activity against the policy, and the works are terminated in case of policy violations.

3.6.PRINCIPLES OF PRIVACY AND PROTECTION OF PERSONAL DATA.

Access to prospective, current or former employee records and personal data, including performance reviews, wages, retirement and benefits, may only be provided by authorized persons and in accordance with data privacy laws. Tunaset processes, stores and destroys all personal data of its employees and customers in accordance with the Law on Protection of Personal Data No. 6698. The sensitivity that should be shown in the personal data of our employees is also shown when protecting the personal data and confidentiality provided by our customers, suppliers and other business partners.

In the commercial communication process, a lot of information is obtained about other companies, including customers, suppliers and competitors. There are some legal and ethical limits to obtaining competitive information. Tunaset expects its employees to act in accordance with legal and ethical limitations.

All rules regarding the Confidentiality and Protection of Personal Data and ethical approaches related to them (KP.07) are strictly applied in accordance with Human Resources Management and sub-Instructions.

3.7. ENVIRONMENTAL AND OCCUPATIONAL HEALTH AND SAFETY PRINCIPLES.

3.7.1. OCCUPATIONAL HEALTH-SAFETY MANAGEMENT.

Tunaset strives to create a healthy and safe environment for its employees, customers, suppliers, subcontractors and shareholders. Achieving this is possible if everyone acts with a sense of responsibility and cooperates. At Tunaset, occupational health and safety is integrated into all business processes and a culture in which occupational health and safety concerns are reported and resolved is encouraged. Personal safety and process safety goes far beyond following the rules. Therefore, every employee and contractor who is in contact with the company should know what to do, how to behave in order to avoid the risk of serious injury and death, and should be alert about safety risks.

All rules regarding Occupational Health and Safety and ethical approaches related to them (IP.00) are applied resolutely in accordance with OHS System Management and sub-Instructions. In this context, Tunaset may agree with an authorized OSGB to conduct Risk Analysis and Emergency Planning and to provide OHS Trainings.

3.7.2. ENVIRONMENTAL MANAGEMENT.

Tunaset voluntarily shares its responsibility to protect the environment. It is committed in Tunaset policies that all Tunaset employees will show the necessary sensitivity in order to protect and develop natural resources and to minimize the negative impact.

According to this;

• The offices and vehicles used within the company are based on security and environmental protection policies.
• By using sustainable practices, care is taken to comply with environmental laws and third-party requirements, and to monitor environmental compliance and performance.

All rules and ethical approaches related to Environmental Management (ÇP.00) Çevre Sis

It is applied decisively in accordance with the tem Management and sub-Instructions. In this context, Tunaset may agree with an authorized company for Risk Analysis, environmental-impact assessment and environmental measurements.

3.8. HUMAN RIGHTS AND ETHICAL EMPLOYMENT POLICY.

Tunaset is committed to respecting and protecting human rights wherever it operates.

It is unacceptable for the following matters to be included in Tunaset. It is not possible to work with a third party that includes any of these clauses in its working conditions;

• Exploitation of children, especially child labor
• Physical punishment method
• Violence against employees, especially based on gender, origin, religion or sexual orientation
• implementation
• Forced or forced labor
• Illegal discrimination in employment and hiring practices
• unsafe working conditions
• Employment below minimum wage, salary cuts
• Illegal overtime practices

For Tunaset, its employees are the most important value, therefore it aims to ensure that its employees and all parties with whom it communicates are treated in an equal, fair and respectful manner and are not subject to discrimination. Tunaset; race, color, religion, gender, age, nationality, language, sexual orientation, marital status, disability, etc. does not discriminate, approaches everyone equally and fairly in decisions regarding recruitment, selection, development and promotion, and expects managers, employees and all parties with whom it is in communication to exhibit the same approach.

3.9. PREVENTION OF CONFLICTS OF INTEREST PRINCIPLES.

Tunaset considers it appropriate to base Tunaset interests, not personal interests, in decisions regarding business processes.

Situations where a conflict of interest may arise are as follows:

• Working in a second job, serving, serving as a manager or consultant, apart from work and business relations.
• Having a financial interest between you and Tunaset's current or potential competitor, customer or supplier.
• Your close relative has any business relationship with you or someone working under you, or with someone working in our business unit, other than official consulting services.
• Undeclared public servant relatives.
• Investing by close relatives in a competitor, supplier or customer of Tunaset

3.10. PRINCIPLES OF NON-RETALIATION.

Retaliation: When you report a situation or person, the person you report, or your managers or colleagues, takes harmful behaviors against you with the aim of punishing you.

The protection of people who make notifications is among our basic principles. Solmaz does not allow any employee who raises a concern in good faith to be subject to retaliation.

Anyone who raises a retaliatory concern against a person or takes action to initiate an investigation will be subject to disciplinary action.

3.11. FAIR COMPETITION CONDITIONS PROTECTION PRINCIPLES.

It is possible for customers to receive the best service in the most appropriate way through free marketing and fair competition.

All anti-competitive behavior is prohibited by law. According to these laws, which prohibit anti-competitive behavior, the violations are as follows.

• Making anti-competitive agreements with competitors, including price fixing, bid rigging, market allocation and restriction of supply
• Sharing sensitive competitive information with competitors
• Imposing restrictions on customers and suppliers
• Abusing the market dominance position
• Making some merger and acquisition agreements

Tunaset expects all its employees to act in compliance with the law.

3.12. DISCIPLINE POLICY.

3.12.1. GENERAL

• The disciplinary procedure is not initiated until the security breach has been verified.
• A formal disciplinary procedure should ensure that investigations of personnel suspected of attempted security breaches are accurate and fair.
• Official disciplinary procedure, an expert (private organization of the institution) who will answer factors such as the nature and extent of the violation and its impact and magnitude, whether it is a first or repeated attack, whether the perpetrator has been specially trained, in terms of relevant laws, organizational contracts and other requested factors. lawyer or a lawyer who is competent in these matters).
• Records are records on paper or all portable information in computer media, drafts and copies of information in hard disk or memory.
• All evidence must be collected in accordance with the evidence collection rules required by law.

3.12.2. INPUTS

• Evidence of security breach
• For documents on paper; records of the original text, who found it, when it was found, and who testified.
• For information contained in computer data; Drafts and copies of all portable data, hard disk or memory information to ensure accessibility.

3.12.3. OUTPUTS

Withdrawal of responsibilities

Cancellation of entry rights,

In cases of serious administrative deficiency, the process is based on the person's duties.

It is ensured that the right of entry is taken away from the company immediately, and if necessary, it is immediately removed from the establishment area.

3.12.4. PROCESS FLOW CHART

3.13. SANCTION.

The provisions of the Labor Law numbered 4857 are applied to all personnel who do not work in accordance with Tunaset Policies.