Compliance guideline
ecoana Kurumsal Hizmetler A.S.

Commitment of ecoana Kurumsal Hizmetler A.S. to undistorted competition

The company ecoana Kurumsal Hizmetler A.S. is active in research and development in the fields of sustainability, nutrition, water science, renewable energy, environmental protection and education. In addition, ecoana Kurumsal Hizmetler A.S. regularly organises panel discussions on topics related to society, culture, social issues, the environment and youth. The aim is to initiate new academic and social initiatives in order to offer perspectives for young adults.

ecoana Kurumsal Hizmetler A.S. is a non-listed corporation in Turkey. ecoana is the patented brand of ecoana Kurumsal Hizmetler A.S. and serves as a communication brand. ecoana thus does not exist as a sole body.

Insofar as monitoring, controlling or quality management systems are in place in the individual sectors and companies, the compliance guidelines are to be incorporated into these systems. Our market economy depends on companies competing with each other for clients (and suppliers) with their services and prices. Competitive pressure forces companies to price their services as favourably as possible and to perform as well as possible. The company ecoana Kurumsal Hizmetler A.S. is therefore committed to free and undistorted competition and strictly rejects any illegal distortion of competition.

Function and objectives of the Compliance Guideline

This guideline serves to prevent violations of legal provisions, in particular competition law and internal guidelines in the companies of ecoana Kurumsal Hizmetler A.S. It is addressed to the employees and the management. Its aim is to provide information on the most important prohibitions of competition law and to establish clear behavioural requirements in order to prevent violations. It focuses on the essential prohibitions that are relevant to daily work. For further questions, appropriate legal advice must be sought. 

1. Responsibility 

1.1 Responsibility for the reputation of ecoana Kurumsal Hizmetler A.S

The reputation of our company is essentially shaped by the appearance, actions and behaviour of each individual employee. Unlawful or inappropriate behaviour by even one employee can cause considerable damage to the company. Every employee is required to pay attention to the reputation of the group of companies in the respective country, and to maintain and promote it.

1.2 Leadership, responsibility and supervision

Integrity and compliance with the law start at the top of the company. Every manager has organisational and supervisory duties to fulfil. Every manager bears responsibility for the employees entrusted to him or her. She must earn recognition through exemplary personal conduct, performance, openness and social competence. This means, among other things, that every manager must always emphasise the importance of ethical behaviour and compliance in daily business, make it an issue and promote it through his or her personal management style as well as training. Likewise, it is a leader's responsibility to set clear, ambitious and realistic goals and to hold himself or herself up to them by example. 

A manager must give his or her employees as much personal responsibility and freedom of action as possible, while making it clear that compliance with the law and internal guidelines is the top priority in all circumstances and at all times. The manager must also be accessible to employees in case of ambiguity regarding legal compliance, questions or professional and personal concerns. However, the manager's responsibility does not relieve employees of their own responsibilities. 

Every employee must be aware of this policy. He or she must have read and understood it. We must work together to comply with the law and internal policies. The following list of specific leadership responsibilities is intended to give employees an idea of the guiding and supporting actions they can expect from a leader. 

The manager is responsible for ensuring that no violations of the law occur in his or her respective area of responsibility that could have been prevented through appropriate supervision. Even when delegating individual tasks, he or she retains responsibility. 

The duties of a manager are in particular: 

• The manager must carefully select employees according to their personal and professional qualifications and suitability. The duty of care increases with the importance of the task the employee has to perform (duty of selection).

• The manager must set the tasks precisely, completely and bindingly, especially with regard to compliance with the legal provisions (duty to instruct).

• The manager must ensure that compliance with legal provisions is continuously monitored (duty to control).

• The manager must clearly communicate to his or her employees the importance of integrity and compliance with legal provisions in daily business and point out that violations of the law are not acceptable and will result in disciplinary measures (duty to communicate).

2. Dealing with business partners and third parties
2.1 Competition law and antitrust law

Fair competition is a prerequisite for free market development and the associated social benefits. Accordingly, the precept of fairness also applies to competition for market share. Every employee is obliged to comply with the rules of fair competition. Antitrust assessments can be difficult, especially because the applicable rules may vary from country to country and from case to case. There are certain types of conduct that can lead to a violation of antitrust law. Employees are therefore not allowed, for example 

• discuss with competitors prices, production output, capacity, distribution, tendering, profit, profit margins, costs, distribution methods or other factors that determine or influence the company's competitive behaviour with the aim of inducing the competitor to behave similarly.

• Collude with competitors not to compete, to restrict business relationships with suppliers, to submit bogus bids in competitive bidding or to divide customers, markets, territories or production programmes,

• influence the resale prices of our customers or attempt to induce them to restrict the export or import of products in the company as a whole.
  Nor may employees acquire competitively sensitive information through espionage, bribery, theft or wiretapping, or knowingly disseminate false information about a competitor or its products or services.

2.2 Anti-corruption: Offering and granting benefits

We win business fairly through the quality and price of our services and innovative products and not by offering undue advantages to others. No employee may offer, promise or grant unjustified advantages to public officials in connection with business activities - directly or indirectly - or approve such advantages.

No payments of money or other benefits may be made in order to influence official decisions or to obtain an unjustified advantage. The same applies with regard to unjustified advantages vis-à-vis persons in the private sector. Any offer, promise, gratuity or gift must comply with applicable laws and internal policies and must avoid any appearance of dishonesty or impropriety.

Thus, such offers, promises, gratuities or gifts must not be made if they could be construed as an attempt to influence a public official or bribe a business partner in order to obtain business benefits for our company. The definition of public official includes, at all levels, representatives or employees of public authorities or other public bodies, agencies or legal entities, as well as officials or employees of state-owned enterprises and public international organisations. In addition, all employees are prohibited from indirectly providing monetary payments or other benefits (for example, to a consultant, agent, intermediary, business partner or other third party) if circumstances indicate that they will be given in whole or in part, directly or indirectly, to a public official for the purpose of influencing an official action or obtaining an unfair advantage, or to a private sector person for the purpose of obtaining an unfair business advantage.

2.3 Fighting corruption: demanding and accepting benefits

No employee may use his or her official position to demand, accept, obtain or be promised benefits. This does not include the acceptance of occasional gifts of symbolic value or invitations to meals or events within reasonable limits, provided that local customs and internal guidelines are respected. Any gift, meal or event invitation in excess of this must be declined.

2.4 Business relations with suppliers

Our company expects its suppliers to share our value principles and to comply with all legal requirements. In addition, we expect our suppliers to apply the following principles:

• compliance with all applicable laws,

• the renunciation of corruption,

• respect for the human rights of their employees,

• compliance with the laws against child labour,

• taking responsibility for the health and safety of their employees,

• complying with relevant national laws and international standards on environmental protection, and

• requesting that these value principles are also implemented/complied with in their own supply chain.

3. Conflicts of interest
3.1 Avoidance of conflicts of interest

Our employees are obliged to make their business decisions in the best interests of the company and not on the basis of personal interests. Conflicts of interest arise when employees pursue their own activities or personal interests at the expense of the Company's interests.  Employees shall disclose to their manager any personal interest that may exist in connection with the performance of their official duties. No employee may have private assignments carried out by companies with which he/she has business dealings in the course of his/her work for our company if this could result in advantages for him/her. This applies in particular if the employee has or can directly or indirectly influence the commissioning of the company for our company or one of its group companies. Further points of conflict may arise from business relationships with or shareholdings in a competitor or customer as well as secondary activities of employees that prevent them from dutifully fulfilling their duties with us. It is important that all employees recognise and avoid conflicts of interest that may arise in the course of their professional activities.

3.2 Secondary activities

This also applies to secondary employment that could represent a competitive situation for our company. The taking up of secondary employment with or without remuneration must be reported to the responsible manager and requires prior written consent.

3.3 Handling company equipment

Our company has a lot of equipment and facilities in its offices and premises, such as telephones, photocopiers, computers, software, internet/intranet, machines and other work equipment such as e-mail and answering machine systems. These may only be used for company purposes and not for personal benefit. Exceptions and, if applicable, payment may be regulated locally, provided that the use of the facilities 

• is not related to illegal activities

• does not create a conflict of interest or the appearance of such a conflict,

• does not result in significant additional costs, disruption of business or other negative impact to the Company, for example, through a conflict of interest with respect to the professional duties of the employee concerned or other employees. In no case shall information be accessed or shared that supports or incites racial hatred, glorification of violence or other criminal offences, or has content that is sexually offensive in the relevant cultural context.

4. Data protection
4.1. Secrecy

Internal confidential or proprietary information that is not intended to be made public is subject to the requirement of confidentiality. Non-public information from or about suppliers, customers, employees, agents, consultants and other third parties must also be protected in accordance with legal and contractual requirements. Confidential or proprietary information may include, in particular:

Details of a company's organisation and facilities, prices, sales, profits, markets, customers and other business matters,

• internal reporting figures. The obligation to maintain confidentiality extends beyond the end of the employment relationship, as disclosure of confidential information, regardless of when it occurs, can be damaging to the business or its customers.

4.2. Data protection and data security

Access to the intranet and internet, worldwide electronic information exchange and dialogue, and electronic business transactions are crucial prerequisites for the effectiveness of each and every one of us and for business success as a whole. However, the advantages of electronic communication are associated with risks for personal privacy and data security.

Effective precautions against these risks are an important part of information technology management, leadership and also the behaviour of each individual. Personal data may only be collected, processed or used to the extent necessary for specified, explicit and legitimate purposes. Furthermore, personal data must be stored securely and may only be transferred using the necessary precautionary measures. A high standard of data quality and technical protection against unauthorised access must be ensured.

The use of data must be transparent for the data subjects, and their rights to information and, where applicable, to object, block and delete must be safeguarded. Some jurisdictions (such as the EU) have strict laws and regulations regarding the retention and use of employee personal data and the data of third parties, such as customers or business partners. All employees are bound by these applicable laws in order to protect the personal rights of others.

5. Environment, safety and health
5.1. Environment and technical safety

Protecting the environment and conserving natural resources are high priority corporate goals for us. Through appropriate leadership responsibility on the part of management and the commitment of employees, our company aims to conduct its business in an environmentally sound manner and is constantly working to improve its eco-balance. Every employee must contribute to these goals through his or her own behaviour. 

5.2. Occupational safety

The health and safety of employees in their workplace is a high priority for our company. Each individual shares responsibility for supporting our company in its efforts to create safe working conditions. Responsibility towards employees and colleagues dictates the best possible precautions against accident hazards and applies to: 

• the technical planning of workplaces, facilities and processes,

• safety management and

• personal behaviour in everyday work.
  The working environment must meet the requirements of a health-oriented design. Every employee must pay constant attention to occupational safety.

6. Compliance implementation and control

The management of our company actively promotes the comprehensive communication of compliance guidelines and ensures their implementation. Compliance with the law and the observance of internal guidelines must be regularly monitored in all companies of the group. The form of monitoring is the responsibility of the individual companies. 

Antalya, 26.02.2021 - ecoana Kurumsal Hizmetler A.S

Zafer Ertem, Chairman of the Board of Directors