Codes of Conduct

With highest technology and many years of experience; we achieve superior results on alloy selection; tight mechanical specifications and constant surface quality.

Purpose

To describe Codes of conduct and instruct all stakeholders to comply with these rules and to ensure that the employees of Erdoganlar Aluminum constantly comply with the Codes of conduct.

Scope

This Codes of Conduct applies to all employees at any levels and executives including the Members of the Board of Directors and Senior Management of Erdoganlar, their affiliate companies and subsidiaries within the country and abroad. They shall be referred to as the “employees” below.

Codes of Business Conduct

The Codes of Business Conduct includes significant behavior, principles and rules of the employees. These principles and rules guide us not only in our daily lives, but also in planning important works and decision-making processes.

This Business Codes of Conduct of Erdoganlar may be amended/updated, when necessary, in accordance with the applicable laws and standards. Our Company’s Codes of Business Conduct is regularly developed and adapted in line with the changes affecting the way we operate around the world.

The image and reputation of Erdoganlar as a company abiding by the ethics and laws also depend on our daily behavior in our business life. As the employees of Erdoganlar, we are expected to comply with laws and regulations, avoid conflicts of interest, protect company assets, and consider and respect local customs, traditions and etiquette in the various countries and cultures in which we operate. While fulfilling our responsibilities within Erdoganlar, we should stick to Codes of ethics. Inappropriate behaviors can never be in Erdoganlar’s best interest

Fundamental Ethics Values and Principles

1. Business Ethics

1.1. Corporation management method

1.1.1. Compliance With Laws and Social Norms

Erdoganlar operates in various product ranges and in many regions of the world. For this reason, we continue our activities subject to the laws of the Republic of Turkey, international rules of law and regulations on moral values. Erdoganlar acts in accordance with the laws and regulations of the countries in which it operates at home and abroad. We keep the information, documents and records regarding these activities regularly and completely in compliance with the Personal Data Protection Law of the Republic of Turkey.

1.2. Data Confidentiality

Confidential information can be defined as information that belongs to Erdoganlar and should not be known by third parties and organizations. It includes any information that may cause material and moral damage to the company and/or all its partners with whom it cooperates, when this confidential information is disclosed. Confidential information can also be defined as financial, technical, commercial, theoretical, personnel personal information and information within the scope of data confidentiality agreement made with the 3rd parties.

We, as the employees of Erdoganlar, attach importance to protecting the private information of our customers, co-workers, suppliers, all other stakeholders, individuals and organizations we work with in compliance with the relevant rules. It is not allowed to share this information with third parties without their consent.

We protect any confidential information regarding the fulfillment of the company’s responsibilities, share this information only with the relevant people and use it for the right purposes. We meet requirements of the Personal Data Protection Law (KVKK) and abide by the rules.

In the event that the employees leave Erdoganlar for whatsoever the reason, they shall not transfer any confidential information, documents, regulations, projects, etc. related to the companies and the organizations they are in cooperation with due to their duties and positions to provide any advantage to third parties in line with their own interests, and not use such confidential information against Erdoganlar.

1.3. Fairness, Equality and Discrimination

Erdoganlar is an employer that offers equal opportunity to each employee.

We approach all our subsidiaries and employees with a fair, honest and impartial perspective and avoid discrimination.

As, Erdoganlar’s employees, we always are impartial in any circumstances and avoid relationships or activities that may potentially prevent taking fair decisions.

Erdoganlar employees also avoid prejudiced or questioning attitudes towards the sub-contractors and the suppliers and do not discriminate against its sub-contractors and suppliers in terms of race, nationality, language, religion, gender, sexual orientation, nationality implications, social origin, political opinion, age, marital or family status, personal relationships, health and social status.

As we adopt the equality as our vision in every field, we offer equal opportunities for our employees, customers, subcontractors and suppliers within the organization, without any discrimination against race, religion, language and sexual preference, to promote especially the “Gender Equality”.

1.4. Forced Labor

As Erdoganlar, we never take advantage of forced labor regarding our employees, customers, co-workers, suppliers and other people and organizations we work with or we never get involved with any forced labor.

1.5. Childlabor

We do not take advantage of and employ any labor under the age of 18, which is regarded as Child and Young Labor in the laws of the Republic of Turkey.

We do not work with any suppliers or subcontractors that use child labor.

1.6. Efficiency, Quality and Continuous Development

As Erdoganlar, we value any kinds of resources to achieve company’s vision and targets and give importance to result-oriented work. We use the time most efficiently in carrying out a project or undertaking a mission to be more efficient and effective and fulfill the responsibility as close to perfection as possible. We always look for a way to make the best of every project and put it into practice.

One of the most important issues that Erdoganlar places emphasis on is to be perfect in its processes to offer world-class products and services by giving great importance to quality and customer satisfaction. Erdoganlar is fully aware of the fact that one of the most effective ways to establish long-term, sustainable and healthy relationships with its customers, to exist for a long time in the industries and regions where it operates and to strengthen its position, is to offer quality products and services.

One of our most important values is to continuously improve the quality of products and services in line with the needs of our customers. Responding to customer demands in a timely manner and in the best way is the primary goal of Erdoganlar, and providing a service beyond the expectations of its customers is one of the performance indicators that we are most sensitive to. Besides offering quality products, we give importance to continuously improve the production and service processes and ensure the most efficient and cost-effective production.

2.Fundamental Business Ethics

2.1. Respect for Human

Employees and prospective employees are assessed based upon principles of equality and fairness. The hiring, compensation and promotion of Erdoganlar employees is conducted in accordance with all relevant laws and regulations.

We strive to create an environment of mutual respect, encouragement and teamwork. We value a sharing environment that provides the opportunity for open communications, continuous learning and diversity.

Since the personal ethical approach may vary according to the community, environment or living conditions of the person in question, Erdoğanlar has organized its operations in line with the respect for human rights so as not to be affected by the differences in their personal ethical understanding.

These are the sources of our strength, today and in the future. Our goal is to provide a workplace environment that attracts and retains highly talented and motivated people, while helping them to achieve their full potential, without regard to their differences or similarities.

2.2.Conflict of Interest

Conflict of interest means that employee accept any financial or other benefit from any material and non-material benefit for themselves, their relatives, friends, customers, individuals or organizations, which affect or may affect the impartial performance of their tasks.

Employees do not enter into a business relationship that provides mutual or complimentary benefits with their family members, friends or other persons. It is expected that our employees, customers, suppliers and other persons and organizations we work with act in accordance with ethical standards under any circumstances. Any personal interests and those of Erdoganlar are to be strictly separated for whatsoever the reason. Thus, all employees should avoid situations that could lead to a conflict between their personal interests and corporate interests of Erdoganlar. XYZ employees are expected to be absolutely fair in dealing with customers, suppliers, and competitors and they should never put their personal interests first.

Working Outside

It is essential that the employees of Erdoganlar not employed by another employer in any way that will prevent them from fulfilling their duties and responsibilities or that will reflect on their work performance, during the periods when they are on annual leave, outside business hours, including the periods when they are sick and on sick leave

In cases where Erdoganlar’s employees are required to act as board members or auditors in organizations that are privately owned; owned by family members, or in any organization other than Erdoganlar; or any organization with which Erdoganlar is not affiliated, this must be notified in writing to the Board of Directors of Erdoganlar in advance. Employees cannot work in any competitor institutions and organizations and Erdoganlar has a business relationship without the written approval of the Board of Directors of Erdoganlar.

2.2.2.Abusing Powers and Responsibilities

Employees should not use Erdoganlar’s name, corporate identity, reputation and power for their personal interest. In addition, employees cannot use the powers vested upon them or the department that they are in charge of for situations that may provide the benefit for themselves and their relatives/next-of-kin. They cannot cause any situations occur against Erdoganlar by abusing their powers.

They cannot use the powers vested upon them due to their positions for their private interests; not act against business ethics, laws and company discipline.

In cases where it is required to use authority, moral and ethical rules should be observed, and no conflict of interest should be allowed before and after the process.

Employees cannot directly or indirectly engage in any activities or situations led by Erdoganlar, in the contracts executed with the customers, suppliers or third-party relations, for purchasing and sales/marketing, for personal interest or profit. In this regard, doing business with Erdoganlar as a supplier, representative, agency or in similar forms, by establishing a company after he leaves the company or his relationship with a company endis a significant issue, which is not favorable.

2.2.3. RELATIONS WITH OTHER PERSONS, ORGANIZATIONS AND CORPORATIONS

Business relationships of Erdoganlar are based on the principles of professionalism, integrity, dignity, courtesy and reliability. Integrity, equality and compliance with laws are of the significant importance. Employees of Erdoganlar cannot have any private business relationship with its customers, suppliers, subcontractors, vendors and any other person or organization with which Erdoganlar has a commercial relationship.

Any humiliating, discriminatory or offensive remarks should be avoided in any written and verbal interactions.

Employees of Erdoganlar cannot borrow any money, accept any special discounts, products/goods or services which are against the business ethics from its customers, suppliers, subcontractors, vendors and any other person or organization that Erdoganlar has a commercial relationship with, or accept any personal benefit for himself or his relatives, even it is of symbolic value. Erdoganlar bases all of its business collaborations on the principles of professionalism, integrity, fairness, dignity, courtesy and reliability. Any humiliating, discriminatory or offensive remarks are avoided in any written and verbal communications.

It is essential that the employees and Senior Management of Erdoganlar take into account the Codes of Ethics and act accordingly when performing any payment and business relations.

2.2.4. MEDIA AND REPRESENTATION

Any statements and press release for information purposes about Erdoganlar are provided to printed or visual media organizations by the individuals deemed appropriate by the Company’s Board of Directors. The Chairman of the Company’s Board of Directors, the Members of the Board of Directors and the General Manager are entitled to make a statement in the media about Erdoganlar or any other persons who are authorized in writing. In case of delegation of authority, the required press release should be made by taking into account the working principles of Erdoganlar. Any activities such as making releases made available to any printed or visual media organization for information purposes, interviewing, and attending a seminar-conference-training as a speaker cannot be carried out without the written consent of the senior management. None of these activities carried out under the leadership of XYZ can be performed for personal gain/profit and cannot be taken advantage thereof. Employees should act in a responsible manner as expected from theirpositions to avoid risks of being associated with Erdoganlar and their posts should not be against the law, nor do they contain offending remarks. In the event that professional or cultural activities are carried out in public, printed or visual media, and personal opinions and suggestions are shared on social media platforms (Twitter, Facebook, Instagram, etc.), it should be noted that no expressions that may negatively affect the reputation of Erdoganlar are posted.

2.2.5. POLITICAL AND SOCIAL RELATIONS

Our company respects the right of its employees to participate in political events individually, but those who participate in political events should make it clear that they do not represent the company.

In addition, the employees can take part in any social and solidarity activities of foundations, professional and social associations as well as associations the company and the employees have or will establish together; provided that they do not interrupt working hours and working order or cause any problems.

Where employees express their personal views in public, they should not refer to their duties and responsibilities within Erdoganlar.

Erdoganlar encourages its employees to become members of clubs, associations and other social, political or cultural institutions with generally recognized and lawful purposes. However, the activities in which the employee is involved should not adversely affect the image of Erdoganlar in the market and sector business world.

Furthermore, such social activities should not adversely affect the employee’s efficiency, sense of justice, integrity and performance while performing his duties at Erdoganlar.

Employees must not engage in any social activities that are against the interests and benefits of Erdoganlar.

Any project, activity or event that XYZ employees are involved in should not conflict with their duties and responsibilities in the company.

In addition, the employees of Erdoganlar cannot engage in any activity or event during working hours, nor do they take the time of their co-workers related to these activities while they perform their duties and responsibilities.

Employees cannot use the company assets (including working time, phones, paper, e-mail, equipment and other assets) while fulfilling or supporting their political activities as well as Erdoganlar’s company name, their positions and titles at the workplace, and company resources

2.2.6.NON-ALCOHOL AND NON-DRUG WORKPLACE

Unconscious consumption of drugs and alcohol may pose a threat to security and is not allowed in the business environment. Any use, possession, sale, manufacture, dissemination, distribution, supply or purchase of alcohol and drugs (other than drugs recommended by a physician with a valid and legal prescription) is prohibited during work or on premises of the company. It is also forbidden for our employees to fulfill their duties and responsibilities under the influence of these substances.

2.2.7. ACCEPTING, GIVING AND REFUSING GIFTS

We do not allow gifts, gratuities or any business courtesies and other benefits to affect our decisions, behaviors and activities to be implemented.

It is essential that the employees of Erdoganlar not accept any gifts/bribes or any object of interest that may positively or negatively affect the impartiality, decision-making and behaviors of them while carrying out their duties in terms of their relations with private or official persons and organizations that want to establish or maintain business relations.

In addition, it is necessary not to make any attempts or not to offer anything that may imply gifts/bribes and other benefits to any persons and organizations with whom the employees of Erdoganlar are in relation. As the employees of Erdoganlar, we assume the responsibility to act in a way that does not create personal connections, obligations or commitments with third parties and organizations.

2.2.8. Principles of practics

  1. Employees or Senior Management should not offer any gifts, entertainment or other gratuities that are of value or that may be regarded as an exceptional and special practice which might potentially affect the individuals and companies’ decision-making organs.
  2. Any intentional gifts or benefits for which something is explicitly expected in return should never be accepted.
  3. Under no circumstances, taking bribes or commissions, giving or even offering such to the other party while purchasing goods or services can be accepted by the management of Erdoganlar.
  4. Employees should not accept or demand any item, service or cash, check, etc., regardless of its value, exceeding the symbolic value for any transaction or business.
  5. Employees of Erdoganlar should refuse all gifts that may affect their impartiality, behavior and decision-making either in a positive or negative way, while fulfilling their duties and responsibilities.
  6. Company Management shall determine the gift or promotional materials that will be given by Erdoganlar to customers, suppliers, consultants, subcontractors, vendors and all other third parties, institutions and organizations with which we cooperate upon approval of the general manager of the company.
  7. Acceptable gifts may include giveaways, calendars, organizers, and chocolates, etc.
  8. All Managers and employees, including the Senior Management, must act in accordance with the gift exchange policy.

Employees of Erdoganlar are not allowed to accept any discounts, money, checks, travel expenses, which may be regarded as inappropriate or complimentary or borrowing money, from his subordinates or superiors, suppliers, consultants, customers, competitors, group companies, any organization or third parties with which they are in cooperation, or to have them to cover their event expenses and similar benefits or to ask them for benefits as described above, for their or their relatives’ own interest.

Apart from the items described in the principles of practice above, employees may also receive and/or give the following gifts, which are appropriate for our corporate culture provided they should not put Erdoganlar in a difficult situation:

  1. Employees of Erdoganlar may arrange catering and meals at acceptable standards in the business world and participate in any events organized.
  2. Employees of Erdoganlar may give or accept gifts of symbolic value, such as an inscribed plaque or statue, as a representation of a business relationship
  3. Employees may accept awards, plaques, statues, etc. of symbolic value as a memoir of the day in seminars, symposiums, interviews and similar organizations where they represent Erdoganlar.

In the event of any gifts, meals, or entertainment exceeding the above-mentioned limitations are politely refused by employees, which should be followed by the explanation of Codes of ethics of Erdoganlar.

If rejecting the gift will offend the person giving it or if the circumstances under which the gift is presented make it impossible to refuse, the gift may be accepted, but the management is informed accordingly. The Ethics Representative or Human Resources Department provides guidance as to whether to give this gift to a charity or dividing it among employees.

2.3.market and competition conditions

Erdoganlar and its employees unconditionally abide by the principles of fair competition, prevent monopolization in the countries where Erdoganlar operates, and also comply with fair competition laws.

2.3.1.Relations and interactions with thecompetitors

Agreements with competitors and coordinated behavior aimed at or causing a restraint or limitation on competition are forbidden. These include agreements to fix or set prices, quotations, terms and conditions of sale, production or sales quotas, and also the apportionment or allocation of customers, territories, markets or product portfolios. Not only formal agreements are forbidden, but also coordinated behavior arising from informal talks or gentlemen’s agreements aimed at or giving rise to such a restraint on competition.

2.3.2. supplier relations

Erdoganlar Aluminum expects all its suppliers and contractors to work in accordance with the Codes of Conduct and to implement its content by approving this document as an annex to the contract.

Erdoganlar Aluminum may audit its suppliers on the implementation of the Codes of Conduct when deemed necessary.

No gifts or benefits that may affect the impartiality, decisions and behaviors of Erdoganlar Aluminum employees are accepted from suppliers and contractors as described in Article 2.2.7.

Any supplier/contractor or its employees can apply directly to the ethics committee of Erdoganlar Aluminum via etik@erdoganlar.com. The applicant can prefer to remain anonymous. However, the title of the relevant supplier/contractor must be specified in the application for evaluation.

Suppliers must immediately notify Erdodanlar Aluminum in writing of any violation of the Codes of Conduct in their area of responsibility, together with a corrective action plan

2.4. treatment of confidential information

Employees are obliged to treat as confidential all internal matters relating to Erdoganlar that have not been expressly approved for release into the public domain.

It is important to protect the proprietary information of Erdoganlar employees, customers, suppliers, subcontractors, all organizations from which they receive or provide services, and their stakeholders. In addition, it is not allowed to disclose this confidential information to third parties without the written consent of the person concerned.

It is appropriate for Erdoganlar employees to protect any confidential information, trade secrets, project details, personnel information, under applicable conditions, and to process and use such information only in line with their duties and responsibilities and in accordance with the purposes of the company they work for. Our employees share this information within the company only within their authority and with relevant persons.

Trade secrets and personal information of Erdoganlar employees, consultants, subcontractors, customers and suppliers, and personal data/sensitive personal data are treated subject to the Law on the Protection of Personal Data (KVKK), No.6698 and relevant regulations.

Except under the circumstances permitted explicitly and permitted by explicit consent, such information and data cannot be used or disclosed. Any information or data related to operations of Erdoganlar is always regarded as “confidential information/information to be protected” by the employees, except for the cases when this information becomes publicly known.

Any information on personnel wages, bonuses, premiums and fringe benefits should not be disclosed to any other employee, and no effort should be made to learn this information from other employees.

Individuals are responsible for the safety of the information kept in all computers, devices and equipment used jointly and personally.

Information and documents obtained as a result of business requirements cannot be shared with unauthorized persons and authorities inside and outside the company for whatsoever the reason.

Only in exceptional cases, if it is required to take the data outside the company for the purpose of processing or using such data, written consent of the relevant data subject or the company’s senior management must be obtained. In cases where such data is shared with the institutions and organizations which Erdoganlar is in cooperation with, a data confidentiality agreement must be signed or a written confidentiality commitment must be obtained regarding the security and protection of the information shared with these institutions and organizations.

2.4.1. avoidance of contractualrisks

Erdoğanlar takes its responsibility to contractual partners seriously. To avoid misunderstandings and unintended consequences, the risk management system of Erdoganlar requires that all employees who bear responsibility for the conclusion of agreements and contracts shall, prior to such conclusion perform a careful assessment of the contractual duties and terms and of the risks that could arise from such agreement. Due to the complexity and legal implications associated with commercial agreements, as well as the potential for conflicts with other corporate relationships, it is the policy of Erdoganlar that Erdoganlar Legal Consultants be involved in the preparation and review of all material contracts as defined by the Company.

2.5. SOCIAL MEDIA PLATFORMS

Employees are expected not to disclose any information regarding procedures, directives or management method on social media platforms (Twitter, Facebook, Instagram, etc.) without information and consent of the Erdoğanlar’s management and not share any unauthorized opinion on a social media platform.

The Ethics Representative and/or the Ethics Committee should be informed about the notifications that are thought to have negative content about Erdoganlar on written or visual social media platforms.

2.6. Fairness, equality and discrimination

We treat all our stakeholders and each other fairly, observe social justice and avoid discrimination. Erdoganlar employees also avoid prejudiced attitudes towards the customers, sub-contractors and the suppliers and do not discriminate against its sub-contractors and suppliers in terms of race, nationality, language, religion, gender, sexual orientation, nationality implications, social origin, political opinion, age, marital or family status, personal relationships, health and social status

2.6.1. fair working environment

No employee or service contractor may be forced to work in our workplace. Erdoganlar adopts non-discrimination principle in job applications in terms of religion, language, race, age, gender, sexual orientation, ethnicity, pregnancy, and approaches every candidate equally and also evaluates them equally. It is one of the most important priorities of Erdoganlar to provide a fair and impartial working environment for its employees and all its affiliated institutions and organizations and to maintain this in a fair manner. It never takes into account differences such as race, nationality, language, religion, gender, sexual orientation, social status, special health conditions among its employees, customers, consultants, subcontractors, suppliers and all institutions and organizations considered as 3rd parties, and always avoids prejudiced attitudes.

The principles to be applied regarding the fair working environment are provided below;

  1. For each employee, a working environment that will support cooperation and be positively guided and evaluated is created within the company
  2. It is encouraged that each employee is given the opportunity to receive training and research to develop and improve himself.
  3. A peaceful working environment is provided for the employees who have different beliefs, religions, social and political thoughts and views by preventing any situations that may arise from possible conflicts.
  4. It is ensured that all practices such as work placement, promotion, transfer, rotation, remuneration, rewarding, change of position, assignment, social benefits, etc., are impartial, in accordance with procedures and regulations, and fair without the intention of deriving profit.
  5. Human resources policies and practices of Erdoganlar operate and are protected equally for each employee.
  6. Every employee is directed to an equal level in order to adapt and keep up with the social and cultural world they live in.
  7. Violation of the personal immunity of the employees through physical, sexual and/or emotional harassment/abuse, violence, by any person in the workplace or in any other institution and organization where they work, and in the environments where events or celebrations take place, is against the law and company’s Codes of conduct. This is not tolerated in any way by Erdoganlar. Any relevant situation is referred to the Ethics Committee; the final result is followed, and the necessary legal actions are initiated. Those who act negatively against the person or persons who complain and report about any violence, harassment or abuse or who assist during the investigation are not tolerated and the relevant action is taken.

2.7. safety, health and the environment

All our employees play an active role in making the locations in which we operate a good place to live and work. Protecting people and the environment, and conserving resources, have long been counted among our core values.

Erdoganlar aims to leave a healthy, clean, livable, transformable and sustainable world to the next generations and to lead the way for the better. For this purpose, we use high standard practices and regulations in our environmental protection activities as per applicable laws, directives and regulations.

We, Erdoganlar, pay attention to complying with environmental obligations and protecting biodiversity in investment decisions and production processes in all geographies where we operate, considering the consequences of environmental pollution and consumption of natural resources.

Erdoğanlar has been and remains committed to sustainable and socially responsible development; the promotion of safe and healthful working conditions; and striving for sustained progress in the fields of safety, health and the environment.

Erdoganlar supports national and international OHS standards by acting in accordance with Occupational Health and Safety Policies, procedures and instructions. It also complies with the regulations regarding OHS. It provides the OHS Basic trainings to all its employees in a timely manner and under appropriate conditions, and implements it by internalizing the OHS requirements. It carries out activities to anticipate and improve the risks related to the work of the employees.

It carries out OHS activities with preventive approaches. It aims to experience zero work accidents.

All employees undertake duties and responsibilities in regulatory and remedial actions.

3. OUR RESPONSIBILITIES

3.1. Responsibilities toward business partners, public officials and other representatives

Erdoganlar is attentive to create resources in areas with growth potential in line with its goal of creating value by placing emphasis on sustainability. It treats its suppliers and business partners fairly and respectfully, fulfills its obligations in the shortest time possible, and shows maximum effort to prevent, resolve and settle any disputes that may arise.

All decisions and transactions of Erdoganlar are reported to the partners accurately in accordance with the regulations. Business relations involving common interests between Erdoganlar and its business partners are carried out with the awareness of social responsibility.

We expect our suppliers, service providers, consultants to respect and comply with our Ethical Principles and Standards.

We are fairly and impartially in our dealings with others, obeying all applicable laws and corresponding regulations governing fraud, bribery and corruption, and avoiding even the appearance of a conflict of interest

3.2. RESPONSIBILITIES TOWARD THE EMPLOYEES

Erdoganlar considers establishing and maintaining a fair working environment for its employees as one of its top priorities. It ensures that the employees perform their duties and responsibilities in safe, healthy and appropriate working conditions. It treats its employees honestly and fairly, committing to a non-discriminatory, safe and healthy working environment. It acts fairly in matters such as education, career, recruitment and promotion, offers equal opportunities, and pays attention to the timely and complete fulfillment of the rights of its employees.

Erdoganlar ensures that the wage and payroll rights of the employees are fully and correctly implemented in compliance with the applicable laws. Erdoganlar makes every effort for the individual development of its employees, provides training, and supports its employees in volunteering for any social and social activities deem appropriate in which they will take part as part of social responsibility.

3.3. responsibilities towards stakeholders and the sector

Erdoganlar competes in all sectors and markets where it operates in line with fair competition rules. Erdoganlar competes with sector companies and competitors in a legal and ethical framework, abides by the rules of competition law unconditionally and avoids unfair competition.

Erdoganlar adopts the principle that fair and honest competition is one of the most important factors for the development of the company and the relevant sector, and accordingly, it manages its operations by promoting a competition based on product performance, development and service quality.

Unlawful arrangements or unfair trading practices with competitors, customers and suppliers are prohibited. There are legitimate reasons and circumstances when dealing with competitors, and unlawful collusive agreements cannot be made.

3.4. responsible purchase

Erdoganlar Aluminum aims to use raw materials, semi-finished products, products and services that are least harmful to humans, the environment and nature in line with its sustainability goals.

In this regard;

Suppliers must comply with regulated substance and product ingredient specifications and all applicable laws, including RoHS, WEEE, Reach, California prop.65 and any other similar laws that prohibit or restrict the use, content or processing of certain substances. Suppliers will forward all information, including but not limited to the official notifications above, to Erdoganlar Aluminum.

Erdoganlar undertakes not to sell products containing “conflict minerals” (tin, tantalum, tungsten, and gold) through any entity that has direct or indirect financial conflicts in the Democratic Republic of the Congo or neighboring countries.

Suppliers are responsible for conducting an adequate review of their supply chain to assess whether products sold or supplied to Erdoganlar contain tin, tantalum, tungsten or gold and, if so, to determine whether or to what extent these metals are sourced from conflict-free smelting facilities. Erdoganlar will be notified of the results of these assessments and will undertake to be “Conflict-Free” so that any such mineral will only be taken from the conflict-free smelting facility.

3.5. RESPONSIBILITIES TOWARD SOCIAL ENVIRONMENT AND PEOPLE

Erdoganlar aims to implement high standards in environmental awareness in carrying out its operations, based on social utility and environmental awareness. Within the framework of its responsibilities to society, it supports education and social aid activities, efforts to increase environmental and social awareness, and cultural and social responsibility projects. Erdoganlar acts sensitively, respectfully and broad-mindedly in terms of the traditions, cultures and customs of its own country and other countries and regions in which it operates. It gives priority to the protection of human health in any practices and takes the respect shown to the environment into consideration.

Erdoganlar contributes to the common interests of society, universal human achievements, preservation of cultural heritage, and development of human well-being.

Erdoganlar values ​​the protection of democracy and human rights at all times. It plays an active role in ensuring that education and charitable works are carried out in the most appropriate way and that they reach the relevant and right people. It attached importance to the elimination and punishment of crime and corruption.

Within the scope of corporate social responsibility, it supports all kinds of ventures, activities and formations that will increase the attempts to move the society forward.

4. APPLICATION OF CODES OF CONDUCT

All employees of Erdoganlar are required to sign a consent letter stating that they have received the training, have read and agreed to abide by the provisions of the Codes of Conduct. The Codes of Business Conduct is kept by a person and persons whom all employees can contact at any time to open and read the rules whenever they want, and get opinions when they remain undecided. Not having read the Codes of Business Conduct or not signing the consent cannot be used as an excuse for the employee’s non-compliance with the principles of the Codes of Business Conduct.

4.1. >ETHICS COMMITTEE

Erdoganlar Ethics Committee has been established in order to prevent violations of ethics at Erdoganlar. The Ethics Committee is responsible for investigating and resolving complaints and notifications that the Codes of Conduct has been violated.

In case of suspected violation of ethics or in cases where any violations are reported, Erdoganlar Ethics Committee is responsible for protecting the company and preventing ethical violations by gathering within 15 days to investigate and resolve complaints and notifications.

If there is no violation or suspicion of violation, the members of the board meet every 6 months to discuss remedial and regulatory activities.

Ethics Committee is a board that Works under the Chairman of the Board of Directors of Erdoganlar Alüminyum San. ve Tic. A.S.

The notifications made by Erdoganlar employees to the Ethics Committee are reserved; besides, reviewing and investigation are carried out in a confidential manner by the members of the Ethics Committee. The Ethics Committee has the authority to assign and direct tasks.

Erdoganlar Ethics Committee consists of the following positions;

Chairman of Ethics Committee: Production and Planning Director

Member of Ethics Committee: USA Sales Department Director

Member of Ethics Committee: Human Resources Department Manager

Member of Ethics Committee: Management Systems Department Manager

Member of Ethics Committee: Financial Affairs Department Manager

Member of Ethics Committee: Opex Division Manager

Member of Ethics Committee: Opex Department Officer

Member of Ethics Committee: Occupational Safety Specialist

Erdoganlar employees are recommended to apply first to the relevant department manager and then to the company’s Ethics Representative directly or via e-mail (etiktemsilci@erdoganlar.com) before referring to to the company.

4.2. ETHICS REPRESENTATIVE (ER)

To lead and consult on the Codes of Business Conduct, a representative will be appointed at all locations of the Company. This representative will be selected by the General Manager of the company and will start their duties upon written approval of the Ethics Committee.

The duties of the Ethics Representative are as the following:

  1. To provide guidance and consultancy on questions and issues raised by employees regarding the Codes of Conduct.
  2. To direct the Ethics Committee when the impression or information is obtained about the circumstances contrary to the Codes of Business Conduct.
  3. To make and direct regulatory and remedial recommendations concerning the Codes of Business Conduct to the Ethics Committee when necessary.
  4. To request information, documents and evidence related to the investigation directly from the respective departments.
  5. To ensure the confidentiality of the information of those who report that there are situations contrary to the Codes of Business Conduct
  6. To carry out activities for the implementation of the decisions taken by the Board.
  7. To take measures that will not violate the principles of confidentiality, if the Board wishes to seek expert opinion, if deemed necessary.

In cases where the Ethics Representative is referred to but not resolved or any situations that are considered to be against the ethical rules, the Ethics Committee can be contacted directly by using the channels below.

E-mail: etik@erdoganlar.com

Erdoğanlar Alüminyum San. ve Tic. A.Ş. Atatürk Mah. Orhan Veli Cad. No:9, Kıraç / Esenyurt 34522 Istanbul

Esenyurt – İstanbul, Turkey T. +90 212 886 55 77

4.3. APPLICATION STAGES

All company employees and affiliated institutions and organizations are entitled to submit their claims regarding individuals or defamation that violate the Codes of Business Conduct to the Ethics Committee by following methods recommended.

In line with the possible investigation, research and document collection that may be carried out following a notification to the Ethics Representative or the Ethics Committee, the particulars of the institutions and persons making the notification is kept strictly confidential.

Issues that cannot be proven true and remain as an allegation, casting aspersions upon somebody and false notifications and that cannot be resolved due to various reasons, are separately evaluated by the Ethics Committee. When deemed necessary, the event can be referred to the Erdogan disciplinary committee for a decision.

Employees can ask themselves the following questions about any issue they hesitate over in terms of complying with the Codes of Business Conduct and can decide whether a certain course of action is ethical:

  1. Is this act/behavior concordant with laws, rules and customs?
  2. Is this act/behavior balanced and fair? Would we be offended if someone else, did it?
  3. Is there any other behavior that cannot cause ethical conflict?
  4. Who might be affected by this act/behavior? Will it have a negative reflection on you or our company?
  5. Do I feel comfortable while disclosing this behavior to my managers?
  6. What would this behavior look like if it was broadcast in the newspaper, on television, and on the Internet?

4.4. reporting violations, enforcement and sanctions

The provisions of this Codes of Conduct represent the fundamental components of Erdoganlar’s corporate culture. We, the employees of Erdoganlar, acknowledge that employees who violate any laws, regardless whether they are subject matters of our Codes of Conduct or other Company policies may be disciplined up to and including termination of employment.

Erdoganlar supervisors may be disciplined for failing to detect a violation in their area, if in the judgment of the Company, the failure resulted from inadequate supervision of employees.

Any complaints can be made in writing by the company management or employees, respectively, to the Department Manager, Ethics Representative and, in the last instance, directly to the Ethics Committee. All documents pertaining to the events requiring the complaint are submitted accordingly.

When necessary, complaints and related documents can also be submitted to the ethics committee verbally. In this case, a report to be kept is signed by the complainant.

The ethics committee review solution methods for ethical violations, actions to be taken, and/or take the decisions for cases to be referred to Erdoganlar disciplinary committee to punish the relevant behavior.

Any applications regarding the events and behaviors that are contrary to the ethical rules can be made by the employees to etiktemsilci@erdoganlar.com or by dialing extension 329 at +90 212 886 5577.

A notification is made in writing specifying the details of the request/complaint using the Form on Notification of Ethical Violation and put inrequest boxes inside the factory. Request boxes are located at points outside the field of vision of cameras recording images to keep the applicant’s identity confidential. It is not necessary to write the name of the applicant or complainant in the relevant letters.

Notifications of suppliers and customers regarding the violations of Erdoganlar Codes of Conduct are made via etik@erdoganlar.com.

In case the applicant/complainant does not want to disclose his/her name, all applications can be made anonymously. Any applications/complaints and notifications made through the above methods will be carefully handled and reviewed.

advice

Erdoğanlar strives to provide its employees with the information and training needed to help employees in avoiding situations that might violate the law, our Codes of Conduct or other company policies. However, in cases of doubt, employees may obtain advice from their line managers or the Legal, Audit or Human Resources Department.

(This section will be completed by the employee.)

On ../../….., I have read and understood the Erdoganlar Codes of Conduct. I accept, declare and undertake that I will not take part in any behavior contrary to the Codes of Conduct

 

 

Name, Surname:

 

Signature: