Acar Basım | Our Ethical Conduct Rules

The aim of Acar Group is to ensure customer satisfaction, provision of products and services which satisfy universal quality and standards by using scarce resources efficiently and contribution to the economic and social development. In this way, it aims to be a symbol of reliability, continuity and reputability locally and globally for its customers, shareholders, employees, suppliers - in summary all of its stakeholders - and, it complies with the laws.

Acar Group has adopted the following principles ;

Customers are our assets,
Being always the best is our indispensable target,
Our most significant capital is our human resources,
Our objective is to create resources for continuous development,
We aim to contribute to the strength of the national economy that gives us our power,
It is our motto to comply with superior business ethics and honest working principles,

The aim of Acar Group is to guide Acar Group employees and those acting on behalf of Acar Group in their decisions and behaviors while performing their duties., by means of Acar Group Ethical Conduct Rules.

All Acar Group employees are expected to display attitudes and behaviors that will ensure the cultural integrity of the Group. In addition to this, all employees are expected to protect and improve the reputability of Acar Group name and the reliability of Acar Group’s corporate structure. Acar Group has also adopted the global ethical and moral values.

All employees, including temporary employees, employed within Acar Group are required to comply with Acar Group Ethical Conduct Rules, as well as Company Ethical Conduct Rules established in accordance thereto. All of our business partners are expected to comply with the business ethics rules and the implementation principles that support these rules.

It is among the primary duties and responsibilities of middle and senior managers working at Acar Group to inform all employees about the Code of Ethical Conduct, to ensure that employees give the necessary importance to these rules, and to make the necessary effort and show leadership in complying with the Code of Ethical Conduct.

It is the responsibility of the Human Resources department of the Company to document that the latest version of the Code of Ethical Conduct and Implementation Principles document has been read, understood and committed by the employee.

As Acar Group, we declare that we will act within the frame of our fundamental ethical values, in case of any circumstances that is not regulated therein concerning the implementation of Ethical Conduct. In case of any doubt, it is essential to seek the opinion of the Company’s Ethical Board.

2 Acar Group Employee Relations

Acar Group aims to be the preferred and ideal organization consisting of the most successful and competent professionals who create the added value that will ensure sustainable growth, and that everyone is proud to be a part of.

Acar Group values its employees and respect employee rights. “Our most important capital is our human resources” is one of the basic principles adopted by Acar Group since the day it was founded. Within this framework;

Seeking the qualification of suitability for work as the only measure in recruitment and employment process, ensuring equality of opportunity without any discrimination,
To ensure equality, at work and compliance with Implementation Principles
Respecting unionization and collective bargaining rights,
To bring the most qualified youth and experienced professionals to Acar Group, who will take Acar Group forward,
To gain maximum benefit from the talents, power and creativity of the employees,
To provide equal chances and opportunities for the purpose of training, guiding and developing the employees,
To reward success by fair and competitive remuneration policies, efficient and objective performance assessment systems and practices,
To increase employees’ commitment to the company by providing equal opportunities in appointment, promotion and rewards,
To ensure peace at work,
To provide clean, healthy and safe working conditions to the employees,
To create and maintain a working environment that encourages transparent and mutual respect, where cooperation and solidarity is the most important element,
To disallow harassment in the workplace by any means,
To evaluate and answer the opinions and recommendations of the employees and take measures to increase the motivation,
To avoid sharing the personal information of the employees with the third parties without obtaining consent and acknowledgment of the employee, unless required legally,
To respect human rights

forms the basic principles in terms of relations with employees.

3 Acar Group External Relations

The key principles that guide the relations of Acar Group with its stakeholders are listed below:

3.1. Communication with the Stakeholders

To represent “ACAR” brand in a way that would not damage its reputation within the society and increase its reputation,
To benefit from their criticism and suggestions by keeping the communication channels open with stakeholders, to ensure the continuation of positive relations,
To make public announcements within the frame of Corporate Information Policy or to seek opinions/ information from Corporate Communication and/ or Investor Relations, to avoid stating personal opinions.

3.2. Relations with Shareholders

To protect shareholders’ rights and benefits arising from the laws,
To make maximum effort to create value in return for the resources provided by the shareholders, to distribute the dividend to the shareholders pursuant to the laws or to transform it into investment,
To ensure that the matters related to the companies to be disclosed to the shareholders and public are announced fully, timely and correctly,
To ensure that the companies are managed within the framework of the principles of trust and honesty that have been going on since the establishment of Acar Group, to manage the resources, assets and working time of our companies with efficiency awareness by targeting sustainable growth and profitability.

3.3. Compliance with Laws and Legal Procedure

To adopt the principle of acting in compliance with all the applicable laws, rules and regulations in the countries where business is or will be carried out, as well as the International Conventions of which Turkey is a signatory,
To manage, record and report the entire business activities and accounting system in compliance with the laws fully and properly.
To ensure that the agreements executed with the third parties and organizations are in conformity with the applicable laws, and ethical rules as well as clear and comprehensible.

3.4. Customer Relations

To create value for customers and to meet their requests and requirements at the highest level,
To provide quality products and services and to pursue consistent policies,
To be professional and fair in relations with customers within the framework of courtesy rules,
To protect the personal information of the customers and privacy thereof in accordance with the relevant laws,
To avoid providing misleading and incomplete information to the customers,

3.5. Relations with the Suppliers, Dealers, authorized Sellers and Authorized Services

To select prospective suppliers, dealers, authorized sellers and authorized services diligently and with care, to ensure that they do not perform unethical and illegal acts, to make the necessary assessments and determinations in line with the relevant implementation principles, to encourage them towards fulfilling their legal obligations, respecting human rights, acting in accordance with business ethics and anti-corruption principles,
To take decisions in terms of objective criteria while selecting suppliers, dealers, authorized sellers and authorized services,
To comply with reasonable confidentiality and occupational safety rules requested in supplier, dealer, authorized dealer and authorized service inspections and visits.

3.6. Relations with Competitors and Competition

Except where permitted by the legislation, to avoid in any event, any agreements and relevant acts that aim to prevent, disrupt or restrict the competition directly or indirectly with the competitors or other persons or organizations, or that lead or may cause this effect. To comply with the provisions of the Law on Protection of Competition and the relevant legislation.
Not to abuse its dominant position in cases where it is dominant in a particular market alone or together with other undertakings,
To avoid communicating and exchanging information with the competitors in order to co-determine the market and/ or rules of competition. To avoid all kinds of negotiations and transactions that may lead to the above mentioned situations in the negotiations with the associations, councils, professional chambers and unions, etc. participated on behalf of the company, as well as during other private or professional meetings and discussions. In addition, if the employee receives any confidential information from the competitors, the employee should inform their immediate manager.

3.7. United Nations Global Compact

As a signatory of United Nations Global Compact, to comply with the 10 principles in the areas of human rights, working conditions, environment and anti-corruption determined therein and to develop and disseminate these principles.

4 Ethical Conduct Rules to be Complied by the Employees

The primary responsibility of Acar Group employees is to ensure continuation and furtherance of recognition of “ACAR” name in terms of professionalism, honesty and reliability. In this framework, Acar Group employees are expected to:

Comply with the laws at all times,
Perform their duties in the scope of fundamental moral and human values,
To act fairly, in good faith and to be understanding in all the relations to ensure mutual benefit,
For whatever purpose, not to gain unfair profit from individuals and organizations, not to take or give bribes, to prevent such acts from being carried out, to act in accordance with anti-corruption rules;
To act in compliance with the relevant business ethics rules and all the implementation principles supporting these rules in the duties pursued and to avoid acting in a way that prevents other employees to properly perform their duties and disrupting the work harmony.
To avoid facilitation payments as a principle (Facilitation payments are: Payments made to public officers such as visa transactions, customs clearance, security or phone service in order to accelerate or facilitate the standard permits or services which are not subject to appraisal).
To avoid any acts, declaration or correspondence that may burden the company with an obligation, unless authorized explicitly,
To take good care of the company’s tangible and intangible assets, including its information and information systems as i f they are personal property and to protect them against any possible loss, damage, misuse, exploitation, theft and sabotage,
Not to directly or indirectly use working time and company resources for personal gain and / or political activity and benefit, whether or not it has monetary value.

4.1. Asset and Information Management

All the company regulations, undertakings and bylaws on asset and information management and confidentiality are regarded as supplemental to the following articles.

4.1.1. Intellectual Property Rights

To ensure timely initiation and completion of legal transactions to secure the intellectual property rights in the newly developed products, processes and software, to prevent sharing of such invention and information with third parties without obtaining written approval,
To avoid -willful- unauthorized use of patents, royalties, trade secrets, brands, computer programs or other intellectual and industrial property rights of other companies in an illegal way,
In cases where confidential information regarding all kinds of intellectual and industrial property rights belonging to Acar Group needs to be shared with third parties, to take the necessary measures in accordance with the relevant procedures to protect our rights.

4.1.2. Information Management

To ensure proper maintenance and archiving of all the records for the required statutory period,
To avoid responding to information requests of third parties, which are regarded as confidential by the company, without obtaining the approval of senior management,
To take meticulous care to ensure that the statements made and reports submitted by the company are true and correct,

4.1.3. Security and Crisis Management

To take the necessary measures and ensure communication in order to protect the company’s employees, information and information systems, plants and administrative facilities against any possible acts of terrorism, natural disasters and malevolent attempts,
To make the necessary crisis planning for emergency crisis management to be established in case of acts of terrorism, natural disasters, etc. and, in this way, to ensure continuity of business with minimum loss at the time of crisis,
To take all the measures to prevent theft of or damage to company assets.

4.1.4. Confidentiality

Acting with the awareness that financial and commercial secrets of Acar Group, information that will weaken the competitive power of Acar Group, employee rights and information, agreements with business partners are within the framework of "confidentiality", to ensure their protection and confidentiality,
To avoid sharing the information and the documents obtained in the course of the job for any purposes whatsoever with unauthorized persons within or outside the company and authorities, and using thereof for speculative purposes (whether directly or indirectly),
To avoid using the confidential information which belong to the companies with which it collaborates and their customers and other business-related individuals and companies in no way other than the anticipated purposes, sharing such information with third parties without obtaining the necessary permissions.

4.1.5. Usage of Social Media

To act in compliance with ACAR Social Media Management Guidelines for any communications and posts on any platforms including social media channels that are not provided or controlled by the company, public forums, personal blogs, social media accounts, web and mobile applications.

4.2. Avoiding Conflict of Interest

Conflict of interest; It refers to all kinds of benefits provided to the employees, their relatives, friends or persons or organizations with whom they have a relationship, and the state of having any financial or personal interest in relation to them, which affects or may affect the employees' performance of their duties in an impartial manner.

4.2.1. Avoiding Transactions in Favor of Themselves and Acquaintances

To avoid gaining any unfair advantage in favor of himself, his relatives or third parties by taking advantage of his title and authority,
To take meticulous care in order not to create conflict of interest with the current employer in terms of personal investments to be made,
To pay attention to the fact that the personal investments or engagements apart from any business activities do not interfere with the current role assumed at Acar Group in terms of time and focus and to avoid such circumstances that may prevent focusing on the main job.
To inform the immediate manager, if the persons holding the position of primary decision-taker at the company in the status of customer or supplier are first degree relatives of the employee.
If the employees have shares in or participate in the investments of another company, other than securities quoted on the stock market, they should notify the Company immediately about the current information and/ or changes in this regard. This issue shall be specially inquired during the job interviews with the candidates. The notification is made to Human Resources and a higher level supervisor and is forwarded to at least two senior managers.
To inform the immediate manager in case of learning that acquaintances hold share or material benefits with another company, with which there are commercial relations.

4.2.2. Representation and Participation in Invitation to Organizations

Except the conferences, receptions, promotion events, seminars, etc. that are open to public participation and organized by the individuals or organization who are actually or potentially related in terms of business, participation in any sports events, domestic or overseas travels that are or may have the impression to be effective on decision making are subject to the approval of General Manager for Acar Group companies and of the Chief/ Director/ Consultant for company units.

4.2.3. Performing Business with the Group After Leaving the Job

If the employee, after leaving the company, establishes a company in their name or collaborates with another company to carry on business with Acar Group as a supplier, contractor, consultant, broker, representative, dealer or similar ways, this may create a negative perception and therefore this is a very important issue which requires attention. If an employee, who left the company, holds a position in the top management or decision taking position at another company, this is an issue which requires special attention.
It is necessary to act in line with the interests of the Group, to comply with moral and ethical rules, and not to allow conflicts of interest before and after the process.
In respect of such a supplier, the relevant manager should contact with the Acar Group company that was in contact with the supplier to prepare a report evidencing that there is no inappropriateness and inform the immediate manager accordingly.
In case of an inappropriate situation, no commercial relation should be established with the relevant person or the company in question.
Except for the exceptional cases which require the approval of Acar Group Work Unit Chief, such commercial relations should not be approved before 2 years as from the date when the employee left the Company in order to avoid any negative perceptions.
An employee, who has left the company, may be reemployed provided that such employee was not dismissed due to failure to comply with any of the principles stipulated in Ethical Conduct Rules and Implementation Principles.

4.2.4. Insider Trading

To be aware that attempting to gain any commercial advantage, including trading securities directly or indirectly at security exchanges, by using any commercial, financial, technical, legal, etc. information of Acar Group or disclosing the same to third parties(insider trading) is illegal, under no circumstances attempting do so.
To take the necessary measures and comply with the confidentiality obligation even after leaving the company.

4.3. Anti – Corruption

Acar Group is against bribery and all kinds of corruption. Corruption damages organizations and their employees in the business life and harms commercial reputation and respectability. Acar Group is extremely diligent and sensitive in fighting against bribery and corruption. All the employees and all the third parties acting on behalf of Acar Group are liable to comply with the anti-corruption rules and the relevant legislation.

4.3.1. To Receive and Give Gifts

Acar Group, in principle, prohibits all employees from engaging in relationships with customers, suppliers, dealers, authorized dealers and authorized services that may create the impression of obtaining material benefits, including the offer and acceptance of gifts, invitations and entertainment.

Below criteria should be complied with in the relations with the private or official persons and organizations who would like to establish and maintain business relations with Acar Group:

Except for circumstances where gifts are given legally and in accordance with the commercial traditions, customary practices and manners or materials having the nature of souvenir / promotion, any gift that may give the impression of the presence of an irregularity, dependent relation or give such an impression (gaining advantage or reference, resulting in the award of a tender, etc.) should not be accepted or offered.
The gifts should never be given in the form of cash or cash equivalent instrument (i.e. Gift vouchers).
No discount or benefit, which may be perceived as inappropriate, should be requested from the suppliers, dealers, authorized services, customers group companies or third parties, offered to third parties and/ or accepted when offered.

5 Occupational Health and Safety

Our Group aims to ensure that occupational health and safety rules are implemented in the workplace and on duty to the fullest extent. The employees should comply with the rules and instructions stipulated for this purpose and take the necessary measures. They adopt the principle that activities for improvement of occupational health and safety is the joint responsibility of all the employees.
The employees shall not keep any belongings or substances in the workplace which may be hazardous to the workplace and/ or the workers or is illegal.
Unless prescribed by a valid doctor report, the employees shall not keep drugs or substances that is addictive or restricting or suppressing the mental or physical capabilities, and shall not perform any work within the workplace or within the scope of the business under the influence of such substances.

6 Non Governmental Organizations and Political Activity

Acar Group companies do not make any contributions to the political parties, politicians or political candidates. Demonstrations, propaganda and similar activities are not allowed within the boundaries of the workplaces. Company resources (such as vehicles, computers, e-mail) may not be used for political activities.

Membership or participation to the activities of any non governmental organization in representation of the company may be done within the knowledge of the Company.

7 Implementation Principles of Ethical Conduct Rules

7.1. Obligation to Notify Breach

If the employees become aware or suspect violation of Acar Group’s or Company’s Ethical Conduct Rules or the law and legislation applicable to the company, they are obliged to notify this to their superior (immediate manager), or if the situation is related to their superior or if the superior does not take any action about the incident that is suspected to be a violation, as the case may be, to the General Manager of the company or the relevant Acar Group Business Unit Chief and ultimately to the Presidency of Acar Group Board of Directors. If applicable, they may also submit notifications by means of the e-mail or phone line established for notification purposes.

Disclosure of any notification made by the employee to the 3rd parties, which may affect the peace at the work place or the business affairs adversely, shall be strictly prevented Any employee who refuses to act contrary to ethical rules and reports in good faith is not allowed to be threatened, retaliated against, or harmed in any way at work or outside of the workplace. Such conducts are considered as violation of ethical rules and the appropriate disciplinary action shall be taken.

It is very important that the person who makes the notification is free from any intentions such as gossiping about the person in question or trying to adversely affect his/her career. In this regard, confidentiality, objectivity and compliance with the ethical rules during the notification and interrogation process is extremely critical. Both the notifying party and the persons who administer the relevant process should give high importance and pay attention to this point.

In case any willful notifications in the form of lie and/ or libel is detected, this will be considered as violation of the rule.

First of all, management gives assurance in order to ensure the appropriate environment and efficiency for the functioning of the notification mechanism. The awareness of the employees are raised to support the management in ensuring the efficiency of the notification mechanism.

7.2. Disciplinary Practice

7.2.1. General

After violation of Ethical Conduct Rules, below disciplinary actions will be taken:

In case of a willful misconduct, dismissal (pursuant to the relevant articles of the Labor Law) and initiation of legal action. The positive works previously achieved performed by the person who has gained unfair benefit willfully may not be a cause for forgiveness, fully or partially, with regards to the decision
If there is no misconduct or in case of any negligence arising from lack of attention or knowledge, an oral or written warning shall be given, as appropriate for the impact of the incidence.

7.2.2. Working Principles of the Ethical Board

The functioning of the ethical rules defined in the Code of Ethics and Implementation Principles booklet and which must be applied in all activities is managed by the Ethics Committee established within the company. Ethical Board consists of the General Manager, Executive Director, Human Resources Director and Legal Affairs Officer.

Ethical Board,

Determines and manages equipment, training and management structure required for the establishment of the system for compliance with the ethical rules and appoints person(s) for these activities, when required.
It performs the duties related to internalization and implementation of the ethical rules across the entire company.
It systematizes the general rules and procedures so that all employees, company shareholders and customers can report violations of ethical rules and any similar regulations.
It provides explanations about the ethical rules, when necessary.
It regulates the necessary reporting procedure for employees to judge and report that ethical rules are violated or someone is forced to violate the rule.

7.2.3. Obligations of the Employees

All employees should

Read the Ethical Conduct Rules and Implementation Principles handbook and undertake to comply with the obligations stipulated therein.
Understand, accept and perform the duties specified in the ethical rules and similar regulations; practice ethical conduct in the course of their work
Report to the ethical board without delay in line with the specified procedures, if they or someone else violates or is compelled to violate the ethical rules
They should know that their lack of knowledge about the ethical rules or similar regulations shall not exempt them from obligations. Employees should submit any issues or questions that concern them to the ethical board.