SUSTAINABILITY MANAGEMENT

1. OBJECTIVE. 

The purpose of this procedure, Tunaset’ all legislative requirements and contractual approach ve ‘Sustainability Managementi’ Principles to definethese principlese , and for the staff who intentionally attempted a security violation is to ensure the functioning of a formal discipline.

1. SCOPE and responsibilities.

1. ISO 37001 this procedure;2016 14064-2018 and ISO Standard, the scope has been prepared.
2. This procedure left thete by the system administrator prepared,General manager approved it.
3. This procedure on the decision of the top management Tunaset’e attached to offices,warehouses,etc.. all of the subsidiaries used inIR.
4. From the implementation of this procedure Tunaset all who work within the staff,and companies to work with us and our customer service foreign firmsMiz is responsible for.

1. APPLICATION. 
   1. TUNASET SUSTAINABILITY PRINCIPLES.

Tunaset’s ethical values, including Sustainability Principles and  Scope is as follows ;

1. The customer Respect and unconditional customer satisfaction
2. Compliance with laws and regulations
3. Work ethics supply chain and our companies promote sustainability
4. Information security requirements
5. Fraud,non-compliance and Prevention of the formation of the state of perjury
6. Anti-corruption and bribery
7. Privacy and protection of personal data
8. Environmental management compliance conditions
9. Occupational health-Safety compliance conditions
10. Compliance with human rights and ethical employment policies
11. Employee and Human Rights Institution of Culture,Talent and career management
12. Preventing conflicts of interest
13. For the Prevention of retaliation
14. Fair competition conditions
15. Investor protection and the win-win Management
16. Corporate citizenship
17. Sustainability priorities,targets and management
18. Transparency,Internal control and Audit,Risk Management
19. Digitization,Cyber Security,Innovation
20. Environmental Impact,Carbon and water footprints tracking of emissions Reduction
21. Performance Indicators,Corporate Memberships,Verification Statements

1.  Customer relations and principles.

Tunaset’of the source and one of the most important assets of Customers.In this context, within the scope of services and/or problems that may occur in the evaluation,solution , and analysis all Tunaset is an issue that needs to keep in the forefront of employees.

Customers ' special requests in the forefront of and satisfaction should be kept of all transactions TC.Laws and regulations should be done within.

Organization and development of the relationship with the customer (KP.04) Customer Relationship Management and (KT.07) Task Definitionsin clearly defined for all staff and these rules without compromising applied.

1. CONTRACT, SUBJECT TO COMPLIANCE WITH LEGAL REQUIREMENTS

1. APPLICABLE LAWS AND REQUIREMENTS

Our organization by applicable laws Tunaset context and defined in document management and timeliness is ensured.Information security controls when determining legal and other requirements relating to contracts are taken into consideration.

1. INTELLECTUAL PROPERTY RIGHTS

All software products that are used in our company is used under license. Materials external materials that are used in the software according to the intellectual property rights to the use of proprietary software products and on the use of legal, regulatory, and in compliance with the requirements arising under the agreements is provided. This process of adaptation policy, and Privacy Policy are secured by instruction.

1. THE PRESERVATION OF RECORDS

Records to be lost, to be annihilated, fraud, unauthorized access and unauthorized release against legal, regulatory, contractual terms and is protected in accordance with the conditions of business. Created and regulatory policies are reviewed at management review meetings for the protection of records. Access to records, storage time and storage conditions are determined according to legal requirements and the organizational conditions (KP.02) Document Managementare indicated in. 

1. CRYPTOGRAPHIC CONTROLS

That is being used in e-government and e-signature applications are available there. Related to these terms is defined in the law. In accordance with this law within the organization can be used. Control and management of these applications is carried out by the relevant ministries. 

1. INDEPENDENT REVIEW OF INFORMATION SECURITY.
   1. REVIEW OF INFORMATION SECURITY

Information security applications,certification audits and surveillance audits of certification bodies and is reviewed by the internal auditors. Non-conformity constitutes the input for management review meetings.

1. COMPLIANCE WITH SECURITY POLICIES AND STANDARDS

Compliance with security policies and standards are reviewed at management review meetings by the top management.

1. TECHNICAL COMPLIANCE REVIEW 

The CPG and the Information Systems Manager and reports received from the cloud by the tests are revised. The results are reviewed at management review meetings. 

1. BRIBERY AND ANTI-CORRUPTION PRINCIPLES.

Tunaset,all kinds of bribery and corruption in the face of ,and the relevant laws,regulations and policies in ensuring compliance with principle.Purpose the purpose of the granting of taking a bribe or corruption to get what's considered strictly prohibited.Such a purpose within the framework of the 3 Tunaset who want to do business with. It is our principle not to continue the business relationship with the parties.

Anti-corruption and bribery Policy for tunaset prepared in accordance with the United Nations Global Compact, a sustainability management is an important part.This is the reason Tunaset’s actions in order to protect the integrity and reputation of corruption and the potential risks are described below.

Tunaset Management policies consistently with the purpose and task of these ,starting with corruption risks, identify,reduce , and manage information to all employees to provide.Employees about the legal requirements to raise awareness to employees that will provide notices the channels of communication open to keep all systems of the official record of transactions done correctly to ensure any unexplained on purpose or not recorded in the accounts,funds,assets and lack of this type of process should be made of all about it is the duty of the top management and to take measures to increase their efficiency.

these procedures and policies to be followed regularly Tunaset general Manager,Customs Brokers,Accounting Manager, the administrator of the system and quality of the Sustainability Working Group (SCG) was established.This is the establishment of a working group (EPL.00.C) the notification document with installation and advertised,duties,powers and responsibilities (EP.00.D) the document has been identified.This document, all as part of sustainability and ethical principles for the protection,control and monitoring from SCG is responsible for.

1. HUMAN RESOURCES.

Human Resources Department,job , recruitment of personnel, duties,powers and responsibilities of the read statement to be signed,the relevant matters, is responsible for training on topics.

The duties of all our employees ,while performingTunaset’in this policy,the relevant legal regulations in force and all anti-corruption laws must be complied with.All offered Corruption Action Staff have been given or received, whether or not aware of the corruption that they are actual or attempted actions Sto CG is responsible for notifying.

1. EXTERNAL SERVICE PROVIDER COMPANIES. 

Outsourced services connections, all the rules and related ethical issues (KP.05) received from outside Services Administration , and the child is applied to the determination in accordance with the instructions.

Support services, including dental services received that firms and business partners, related policy guidelines and other regulations with compliance to provide those who violate them are required, and people and organizations with relationships again review is passed.

The upper level of valuation, external companies and business partners of the service provider selection phase, experience, financial performance, technical competence addition to criteria such as the moralite , and in this area a positive history have in fact taken into account. Bribery or corruption intelligence with companies that have negative relationships to re - review is passed. In this context, the necessary research and evaluations to be performed is the responsibility primarily of senior management.

Positive intelligence and other criteria that meet with business partners and companies to be made, Agreement , and contracts;

•  Policy-related rules and other regulations ensuring full compliance 
• Employees on these principles absorb and act accordingly, 
• Periodically, employees, Policy, training, allowing you to receive, 
• Employees with the notification obligations related to regular and a reminder to send such situations one encounters to make notification in case of encourage - related conditions shall include, and that they comply with them or a situation that is contrary to policy failure occurs in case that the study be terminated relating to the provisions of this is brought to. 

The company or its business partners of the promise of monitoring its compliance with the matters the subject primarily Tunaset of top management responsibility.

1. Representatives and agents.

The delegate and to use the tool acts of corruption that can cause high risks pose can. This risk, however, is a tool in high - risk countries operating to may be made. 

Third persons committed Corruption Act,Tunaset by processed can be counted sincethe tool in this area this Privacy Policy and the use of other procedures must be compatible. 

Tunaset’s reputation would damage and mediate the task of qualifications in relation provides that to be taken to ensure foradequate and careful review yapilmamis which any tool should not be. 

1. GIFTS

Our employeesof any transaction or business for 200 TL (Two Hundred Turkish lira) in excess of a goods/services, or value , regardless of cash, cheque , etc. of interest, demand, supply and can't accept. Our company or to impress a nature to affect their decisions and preferences, which is aiming gifts or other gifts should not be accepted, this kind of claims should be made. 

Company policy in accordance with the main rule is not to accept the gift, although it is below, as specified protected , provided there is not any harm in the present adoption: 

• Possible it is , if in advance to supervisor about this, or immediately afterwards informed, be
• To provide any performance benefit or unfair to each other by way of explicit or implied as mutual advantages or benefits in order to provide a third by impress, incentive or reward that is made with the intention of not 
• Is in compliance with national legislation,
• As an individual, not the company as, to be provided 
• Cash or cash equivalent value that do not contain a provision (such as gift certificates or vouchers), 
• The concrete situation of the conditions to be appropriate (for example, in Turkey for Christmas small gifts giving is customary), 
• The gift of an appropriate value , and to be given at an appropriate time (for example, the tender during the period of catering/hospitality are not accepted.) 
• Hidden and it's not, clear in a manner to be given. 

This set become available, even if any manner, public officials, politicians and representatives or gifts to political parties and/or shall be served, and gifts from them and/or are not offered.

In addition to this set;

•  IFA impress an unfair, incentive or reward with the intention of a payment, gift giving, or a treat, promising to be, or be offered, 
• A routine operation “easing” or accelerating for a public officer, agent, or representative, to the payment, gift giving a treat or promised, or offered, is strictly prohibited.

1. HOSPITALITY

Hospitality, sponsorship the company outside of a person or other a company by that is performed in an event or activity. Hospitality events/activities among the following include: 

• Social events   
• Accommodation
• Dinner

The company hascommercial relations improve and the normal commercial communications on a network setting up the work for third parties, the hospitality can offer. These third parties between clients, consultants, lawyers, auditors and companies between trading relationship on other companies (employees, families and friends , including the staff. The company, provides hospitality publicly, good faith, and unconditional as to offer. 

Hospitality offerings of personal or linked to the contacts (family members, friends, close relationship in the people , etc.) the name of the adoption for the same principle applies. The company might not be in compliance high valued a hospitality offer when you're connected to the unit manager approval must be obtained. 

Even if they comply with the policy stated in interest to a conflict of the way could lead or leading to situations that are perceived that way that should be given, in such cases, the hospitality bids should be submitted or should not be accepted. 

1. OPERATIONS FACILITATING PAYMENTS.

Tunaset the scope of this policy which are in people and organizationswith government agencies on a routine operation or process (obtain permits and licenses, to obtain the document, etc.) secure , or accelerate to facilitation payments does not allow to offer. 

1. JOB OFFERS.

A business proposal of (temporary or permanent) the act of corruption by any means that might be the impression eliminate tothese proposals is the “normal based on competition if the import process outside” customers, business partners (they are closely associated to be known to third parties) or the civil servants and public officials (or with government officials closely connected is known persons) is not made to the general principle.

1. THE POWER OF ATTORNEY GORDURULE BUSINESS WITH FIRMS.

Tunaset, serving as a representative, management consultancy engaged in accounting, payroll, information technology and facility management , such as functions with interested agents, suppliers and contractors , such as people and/or institutions entered relations, 3.the person bribe giving my sense of Taken has, or is suspected person or institution with a relationship should not establish, if the promise is the subject of the type of a sense of receipt as of the date established in a relationship is detected, the corresponding gets a warning; not a sequel of warning in case of commercial relationship is terminated. 

Tunaset with a relationship and work on its behalf by proxy by establishing who the individuals, suppliers or contractors oflegal regulations and applicable for all corruption fight should be in agreement to comply with laws. 

1. POLITICAL DONATIONS.

Tunaset by no donations for political purposes are made.

1. Charity donations and sponsorships.

Tunasetrequested help for the purposes of contributions and sponsorships, however, legal,Tunaset by issued regulation, policy, directive and regulations are also compliant with applicable must be in compliance with local laws. 

Help the purpose of each contribution and sponsorship, open and transparent a manner must be made. In this case, the recipients of the selection for transparent criteria should be determined.

1. Corruption and anti-bribery POLICIES.

Tunaset’corruption acts against the tolerance is zero.Tunaset employees and/or third persons,Tunaset with the process in any action, tolerance to corruption are not shown.

Our employees, their duties , fulfilling the third a person with any form of bribe that could be perceived as the nature of any payment or third persons with dealings against to propose it to the side, promises, to ask, to demand, to give or to accept tolerance does not show.

All of our employees to bribery in relation to the rules of the company issued in accordance with the rules of ethics and compliance with the act is responsible.

1. Notification of violations, corruption and bribery.

Protect the reputation of our company tocorruption fighting rules for reporting any situation of violation of all employees it is the responsibility of the individual.

Any employeein case of violation of the rules in this policy are informed Sustainability Working Group.

Cases of violation of the reporting of acts of corruption, which has been noticed to fail or ignore corruption arrival also fighting within the scope of an infringement of the rules will be evaluated. 

All our employees for corruption fighting or questions regarding this policy and those who violate the rules specified in the policy of reputation and our trust that could damage the suspicious situations should be reported.These notification and Management to analyze situations by e-mail or suggestions@tunaset com can be reached via.

1. Anti-corruption rules of the violation and its consequences.

Our managers and all employees of their business when conductingbusiness of this policy, the relevant legal regulations and applicable for all corruption Combating to comply with the law are required.

Lack of knowledge of the rules in this policy, the violation for cannot be accepted as an excuse. 

Violation of this policy in the event of termination of employment, depending on the nature of the event, which may go up to disciplinary action up to and the agenda can come. 

Also the relevant legal regulations and applicable for all corruption to fight those who violate laws forcriminal liability may be exposed. 

On behalf of the company or external service provider companies to the task that makes people and organizations made in the contract in violation of the policy, behavior, attitudes case of determining that there is or activity studies will be terminated provisions in the case of a policy violation and will also include the work is terminated. 

1. Privacy and personal data protection principles.

Performance evaluations, pay, including pension and benefits to prospective,current , or

ex - employee records and data privacy laws and only by authorized persons have access to personal data

appropriate as may be provided.

Tunaset,employees and customers personal data protection Act No. 6698 all personal data

appropriate processes, stores and destroys. Sensitivity of the personal data of our employees is required to be disclosed

in the same way, our customers, and confidential personal data provided by suppliers and other business partners

protecting illustrates.  

Commercial customers in the process of communication, many other companies, including suppliers and competitors

the information is reached. Competitive information about how to obtain certain legal and ethical limits there are.Tunaset expects employees to adhere to legal and ethical restrictions.

All rules and related ethical issues regarding privacy and protection of personal data (KP.07) Human Resources Management , and sub Instructions, in accordance with the determination to be applied.

1. ENVIRONMENTAL and occupational health and safety principles.
   1. OCCUPATIONAL HEALTH-SAFETY MANAGEMENT.

Tunaset employees, customers, suppliers, sub-contractors and shareholders for healthy

and strives to create a safe environment. To achieve this everyone

responsibility to act with awareness within the business community.

Tunaset’te all business processes are being integrated into occupational health and safety, and occupational health and

safety concerns about reported can be resolved where a culture is encouraged.

Personal safety and process safety is about more than following the rules. So

the company who are in contact with each employee and contractor, serious injury and death

the risk to avoid, what to do, how to behave should know the safety risks

about must be vigilant.

Occupational Health and safety in respect of all rules and related ethical issues (IP.00) OHS management system in accordance with the instructions and sub the determination is applied.Tunaset in this context, risk analysis and emergency planning and training to give you a competent and osgb ISG can agree with.

1. ENVIRONMENTAL MANAGEMENT.

Tunaset willingly shares responsibility for Environmental Protection. To protect natural resources, enhance, and

the negative effect to minimize all Tunaset of employees to show the necessary sensitivity Tunaset

in politics are being committed.

This is according;

• The company used in offices and vehicles are acted on the basis of safety and environmental protection policies.

• Sustainable practices by using third-party requirements with environmental laws and compliance,environmental compliance and performance monitoring are given.

Environmental management and sustainability and related ethical issues related to all rules (CP.00) environmental management system is applied to the determination in accordance with the instructions and sub. Tunaset in this context, Risk analysis,environmentalimpact assessment to dota need and if it finds an authorized company may be able to negotiate with ambient measurements.

1. Human rights and ethical employment policy.

Tunaset is committed to the protection of human rights and respect human rights wherever they operate.

The following issues Tunaset it is unacceptable to be located within. Any of these goods in question to work with a third party that hosts operating conditions is not

• The exploitation of children in child labour

• A method of physical punishment

• Employees, particularly gender, origin, religion or sexual preference of violence on the application

• Forced or compulsory execution

• Employment and recruitment practices, unlawful discrimination

• Unsafe working conditions

• Under the minimum wage, man running, salary cuts

• Illegal overtime applications

Tunaset employees, for the most important value of this reason, employees and all parties in the communication are equal,

fair to be treated in a respectful manner and aims to ensure that they are not subjected to discrimination.

Tunaset; race,color, religion, sex, age, nationality, language, sexual preference, marital status, disability, etc. implementation differences,

 job recruitment, selection, development and promotion in an equal and fair decisions about the approach, managers, staff, and expects all parties to take the same approach to communication.

1. THE PRINCIPLES OF THE PREVENTION OF CONFLICTS OF INTEREST.

Tunaset not tunaset interests personal interests in decisions about business processes

basic finds it convenient to be taken.

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

• Business and business relationships outside of work a second job, serving, director or consultant

as to serve.

• Tunaset’s current and potential competitor, supplier, customer or between you and

financial interest.

• Someone who works with you or under you or your close relative working within a business unit

someone have any official business relationship with the exception of consulting services.

• Public officials and relatives of undeclared.

• Close relatives Tunaset’in a competitor, supplier or customer of the investment you make

1.  PRINCIPLES FOR THE PREVENTION OF RETALIATION.

Retaliation: any situation or person you have reported you to your manager or colleagues report in order to punish the person or against you due to destructive behaviors.

Among our fundamental principles for the protection of the person who made the notification is.Tunaset, reported a concern in good faith and do not allow any employee to be exposed to retaliation.

A concern for retaliation against a person or persons who acted in about launching an investigation will be subject to disciplinary action.

1. FAIR CONDITIONS OF COMPETITION PROTECTION PRINCIPLES.

Customers the best service in the most appropriate way for you to receive by way of the free market and fair competition possible.

Anti-competitive behavior is prohibited by law. Competitive behaviour that prohibits violations of the law are as follows.

• With competitors, price fixing, bid rigging, allocation and supply restrictions on Sunday, including making agreements in violation of the competition

• Competition-related share sensitive information with competitors

• Impose restrictions on customers and suppliers

• Abuse of dominance position Sunday

• Some contracts for mergers and acquisitions

Tunaset expects its employees to comply with all laws.

1. DISCIPLINE POLICY.
   1. GENERAL
2. The disciplinary procedure was performed without verifying that the security breach will not start.
3. Formal disciplinary procedure in the investigation of suspected security breach that tried to accurate and that should be taken to ensure personnel were fair.
4. Formal disciplinary procedure, the impact and magnitude of the violation with the size and nature of this work, the first or a repeated attack, whether it is the person who made the breach are not trained specially trained and factors such as relevant laws, organization, contracts, and other factors that are required to answer in terms of an expert (the institution's private attorney, who has competence in these matters, or a lawyer) by is provided.
5. Records paper records or information that are found in the environment on all the portable computer hard disk or in the memory draft and the information contained are copies.
6. All evidence should be collected in accordance with the rules of law of evidence as a condition.

1. ENTRIES 

1. Evidence of a security breach
2. For the documents on paper; the text originaltext was found, who, when, and who witnessed the related records.
3. Computer information that is included in the data; to ensure access to ensure that all of your mobile data, drafts and copies of information that is contained in the hard disk or memory. 

1. OUTPUTS 

1. Responsibilities suspension
2. Revocation of rights of entry
3. In the case of serious deficiencies in the administrative process, the person's duties, Rights get taken away for the introduction of immediately, if necessary, the organization field is taken outside immediately.
   1. PROCESS FLOW CHART 

1. SANCTION.
2. 
   

Tunaset all about the staff who work in accordance with policies 4857 runs in Business Law provisions are applied.