1-PURPOSE:

This Code of Ethics Procedure, Egem Metal Profil Ve Nak. Work. Hr. San. In order to improve the reputation of Tic. Ltd. Şti in commercial and other economic activities; It sets standards for the implementation of the code of conduct, which must be followed by all employees, regardless of their specialty, nature and position. Norms of the procedure; It regulates the situational behavior of employees according to the principles of morality, honesty, justice and partnership, which are necessary for the successful operation of the company.

2-SCOPE andRESPONSIBILITY:

Our code of ethics is an important element both for the success of our Company and for personal success. It is the responsibility of our managers to create an environment in accordance with ethical principles in all departments of our company. In this context, our managers,

• Our ethical principles and the law and regulations to which our Company is subject accept the importance and remain bound under all circumstances.
• It sets an example to its employees with its behavior and thoughts.
• It adopts the application of ethical principles in our Company as its top priority.
• The establishment of company culture works to ensure that employees are enforced into the norms and values that they must adhere to.
• It creates an environment where teammates can communicate openly and will not hesitate to bring ethical issues to them as well as problems that may occur in all transactions of the Company.
• He always acts consistently in his behavior and decisions.

It covers the employees in all locations of Egem Metal.

The Human Resources and Administrative Affairs Department and the Security Control and Audit Department are responsible for the implementation of this procedure.

 3-DEFINITIONS:

1. Representation costs: These are the official reimbursement and/or reception expenses of the representatives of other companies participating in the negotiations in order to establish and (or) maintain mutual relations.
2. Business ethics: It is the set of rules that regulate the relationships that arise in the process of business communication.
3. ABOUT US culture: It is the values, beliefs, traditions and norms of moral behavior that are mandatory for all employees of the company and determine their behavior.
4. Company resources: It covers tangible and intangible resources such as the people owned by the company and employed by the company due to its activities, the machines, materials, tools, intellectual property, reputation, information and information resources, documents, communication tools and communication channels, software and cash.
5. Confidential information: In accordance with the legislation of the Republic of Turkey, it means information with limited access, which does not contain any state secrets, and has limited access.
6. Conflict of interest: Situations that arise due to activities, interests or relationships that are assessed by the employees of the Company to affect or are likely to affect the interests of the Company.

3.1-USE OF COMPANY RESOURCES

The protection of the Company's resources against theft, wasteful use or personal interests and personal purposes is ensured through the interactive work of the Company's employees, units specially established for these purposes within the Company and security units.

In order to ensure the efficient use of the company's resources, the following are the things that every employee should do (but are not limited to);

1. To do its utmost to prevent wasteful use, theft and personal use of the Company's resources,
2. To use communication and communication facilities (telephone, internet connection, e-mail, etc.) only for the purposes related to the Company's business,
3. In accordance with the legislation of the Republic of Turkey and within the framework of trade secret normatives in force within the Company, to protect all electronic programs, data, contact information and written documents against access by third parties,
4. To use the Company's resources, employees and assets in accordance with the legislation.

The Company shall not rule out the possibility that in some cases employees may be obliged to use electronic communication facilities, office equipment and tools of the designated authority for purposes other than those related to the Company's business.

In accordance with the legislation of the Republic of Turkey, the Company has the right to demand compensation from the employee for the damages suffered by the Company due to the contrary behaviors related to the above.

4.1. Representation Costs

1. Representation costs are used for clients and business meetings.
2. Representation costs are used only in the areas to which they relate, and cannot be switched between areas of expenditure.
3. No invoice is obtained from elsewhere for the expenditure for which an invoice is not received. If necessary, an expense slip is issued in accordance with the laws and the expenses are not hidden by receiving different invoices.
4. Managers can buy gifts for their employees for reasons such as creating team spirit, rewarding, increasing motivation and so on, and take them to dinner, theater, concert and similar places. There is no discrimination among employees in carrying out these activities.

1. TimeManagement

Time is one of the most important resources of the Company. It is essential that the employees of the company use their working hours efficiently and do not allocate time to their private work during working hours. Managers may not assign their employees for their personal affairs. It is the responsibility of the meeting organizer to ensure the effectiveness of the time allocated to the meetings and it is essential that all participants come to the meeting in preparation. All attendees respect the start and end times of the time allotted for the meeting.

It is essential that no special visitors are accepted during working hours, and in special and exceptional cases, the meetings of the employees with the visitors from outside should not exceed 10-15 minutes.

1. RELATIONS

6.1- Relations with Suppliers

The following points are taken into consideration in relations with suppliers. Egem Metal employees carry out their activities in an ethical and honest manner under all situations and conditions, comply with human rights principles aimed at supporting and protecting human rights, protect the environment and contribute to the society in which they are located. All our employees act in accordance with the Supply Chain Code of Ethics and Rules that regulate our relations with the Company's suppliers.

6.2-Customer Relations

Within Egem Metal, customer satisfaction is based, keeping their needs and demands in the forefront; We work with an understanding that responds to customer complaints and demands in the shortest time and in the most accurate way. Even if it is in favor of the company, customer weaknesses cannot be exploited and the customer cannot be profit-oriented by giving incomplete or incorrect information.

1. Customer complaints are immediately recorded in the management system and directed to the Customer Complaints Committee. The reporting of customer complaints to the senior management is meticulously carried out by the relevant units within the principles of transparency.
2. Employees may not enter into a special business relationship with the Company's customer, borrow money, and no money can be lent to the customer.
3. The purchase of goods or services from the customer at a fraction of its value or without any compensation is considered as a gain of interest and requires disciplinary action leading up to the termination of the employment contract.

1. 6.3. Relations with the Media

It is up to the approval of the General Manager to make a statement to any media organization, to conduct interviews, to attend seminars, conferences and similar places as a speaker and to determine whether a fee will be charged in return. In no way can personal gain be derived from these activities.

1. 6.4.Relations with Public Authorities

Relations with public authorities are carried out within the framework of laws and Company policies / procedures. A written record is created for the information requested by the official authorities and the General Manager/Legal Counsel's Office/Related Directors are informed. The relevant persons are informed accurately and in a timely manner.

1. OBLIGATIONS TO THE COMPANY

1. Acceptance of Gifts, Invitations, Aid and Donations

1. GiftAcceptance

Gifts cannot be requested or implied from customers, suppliers and consultants, and no benefits such as gifts, money, checks, property, free holidays, special discounts that will put the Company and the field under obligation are acceptable.

However;

1. 250 TL and its equivalent is less than the equivalent amount of foreign exchange,
2. If it is not accepted, it is highly likely to adversely affect customer relations,
3. Gifts that are foreseen not to affect the financial decision to be taken if accepted may be accepted provided that a senior manager is notified. Gifts that do not meet the specified criteria are rejected by an appropriate method.

1. Invitation Acceptance; invitations to dinners, business meetings and social activities made by third parties that do not affect the decisions of the personnel participating in the invitation, do not contradict the policies and interests of the Company; it can be accepted provided that the approval of a senior manager is obtained.
2. Acceptance of Aid and Donations; Help and donations from any person or organization that has any account relationship with the Company in any way are acceptable. The donations and aids offered are shared with a senior manager in each case.

1. Not to engage in activities that may create a conflict of interest

Conflict of interest; It is the inverse relationship between company interests and personal interests and customer-facing interests. Personal interests cannot be put above the interests of the Company. The position within the Company, the property of the Company, the service information cannot be used for personal interests.

In the case of a conflict of interest or when there is any doubt about whether there is a conflict of interest in any matter, the situation is shared with a senior manager.

It is not appropriate for our employees to purchase services and materials from our suppliers for their own special needs at prices and conditions better than the prices and conditions received by the Company or in a way that exceeds their own needs and reaches commercial dimensions.

This shall be clearly stated in the proposals made by the Companies in which the members of the former Company are directly / indirect partners or employees and in all kinds of works with these Companies and the approval of the Board of Directors shall be obtained.

In the case of family members and close relatives working in Supplier Companies and customers, these relationships are not allowed to create a conflict of interest. In such cases, the approval of the Board of Directors is obtained before establishing a commercial relationship.

Employees who have the authority to make purchasing decisions; they do not make a purchase decision in the bids made by the Companies in which their family members, close relatives or friends are direct or indirect partners. A purchase decision may be made provided that this situation is clearly stated in the evaluations, that it is in the interest of the Company and that the Board of Directors is informed about this issue and that it is approved.

Except for our employees who are in contact with customers and suppliers due to their work, it is not appropriate for other employees to be in close contact with these people.

Egem Metal employees,

• It cannot obtain any special benefits from the customers and cannot transfer the benefits by establishing an intermediary relationship between the customers.
• When there is a conflict of interest between customers, it treats all customers equally and fairly.
• It strives to perform its duties impartially.
• In order to prevent conflicts of interest, the personnel are obliged to comply with the following rules.
  • Not vouching for customers and not accepting their bail,
  • Not to enter into relations with customers that are incompatible with professional practices such as debt-credit relationship, etc.,
  • Not to participate in invitations or domestic/international travels paid in whole or in part by customers, except in cases where there is the knowledge and permission of a senior manager,
  • Not to accept uncommon gifts from customers of a nature and value that may give rise to liability for them,
  • Not to give excessively expensive gifts to existing or potential customers and not to use their position to provide advantages (e.g., special discounted shopping opportunities) that exceed the client's business area and go beyond normal practices.

1. Doing Business Outside the Company,Taking Duty

Employees; may not engage in activities that require them to be considered as merchants, tradesmen or self-employed persons, nor may they be partners in Companies (except for purchases of shares through the stock exchange for the purpose of evaluating savings from Companies traded in the capital markets). In all kinds of Company and commercial enterprises, the merchant or tradesman cannot take part in paid or free duty. Except for the Company's subsidiaries and affiliates, he/she cannot be a member of the Board of Directors of other Companies.

Taking part in institutions and organizations related to the activities of the Company or operating for social purposes such as cooperatives, professional chambers, unions, professional and social associations, foundations, federations and confederations, etc. is carried out with the approval of the General Manager.

Provided that the employees with expertise do not disrupt the work, it is subject to the permission of the General Manager to give lectures in vocational conferences, universities and vocational schools.

1. Workplace and appearancerules:

Workplaces, production and administrative facilities should be organized in accordance with the rules of occupational health and safety and fire safety, in such a way as not to interfere with ergonomic, aesthetic and work functions.

The Company undertakes to provide employees with the necessary work clothes, work shoes and other personal protective materials in accordance with the working conditions and seasons.

Employees who do not take their work clothes and shoes due to their position do not have to dress as one style. However, clothing should be suitable, modest and habitual to the business environment.

1. Political Activities

The personnel of the Company may not provide material and moral assistance to political activities on behalf of the Company or on behalf of themselves, even if they have financial means. He cannot be an active member of any political party during his term of office. Managers may not ask their employees to do political work or to become members of a party.

1. Discrimination

Discrimination that may arise in terms of age, language, race, health status, gender and marital status is contrary to workplace rules. The Company shall punish those who violate these rules in such a way that they may go up to the termination of the employment contract. Employees can report their complaints in this regard to the Human Resources Directorate, bypassing all their senior managers. Any complaint in this regard cannot be prevented from being forwarded to the Human Resources Directorate.

1. Personal Aid andDonations

Employees of the Company may personally help third parties outside the Company, make donations, and take part in charitable associations provided that they notify the Human Resources Directorate.

1. GENERALRULES

All our employees,

1. 11.1. Protection of the trademark,
2. 11.2. To comply with the principle of professional confidentiality,
3. 11.3. To protect the personal data of employees, customers, suppliers and other business partners required by their business,
4. 11.4.To fulfill their duties honestly,
5. 11.5. To ensure that the Company's assets are meticulously protected,
6. 11.6. It is obliged to comply with the legal regulations and all policies and regulations published by the Company.

Employees are obliged to follow the instructions given by their superiors in the upper position. However, if any personnel believes that the instruction received is contrary to the legal regulation and/or all policies and regulations published by the Company to the code of ethics or the application style of these rules, they should notify this situation by message to the supervisor in a higher position from the instructor and/or to the e-mail address specified on the ethical principles. Such an act does not put the reporting staff in the position of the accuser for any reason.

11.1- Protection of the Trademark

The Egem Metal brand is our most important value, from which we draw strength in all our activities. Our primary goal is to protect and raise the strong reputation of our brand in a consistent way in line with our marketing and communication principles. Our employees are obliged to perform their duties with the principles of protecting and raising our brand.

We know that personal social media accounts are everyone's private spaces, and we respect their sharing preferences. However, social media accounts are made with personal e-mails other than Company e-mails; that our employees refrain from sharing content that would cause disagreement, uncertainty or that represents the Company in their use of social media; we expect them not to share information and photos that would violate privacy rules.

11.2- Professional Confidentiality

Our employees are under the obligation not to disclose all kinds of information related to the activities and transactions of the Company to anyone other than the legal authorities and authorized employees of the Company, which are explicitly listed in the laws.

In the course of the performance of their duties in the internal activities of the Company, our employees who have knowledge of a confidential and/or first-hand obtained Company information and not disclosed to the public cannot transfer the confidential information they have learned to persons other than those who need to learn that information.

"Confidential information" includes all kinds of Company information that our employees have learned in writing or orally or electronically due to their duties, which may be obsolete, current or obtained.

Employees may disclose confidential information that they are aware of due to their duties only to other employees of the Company who are required to learn confidential information within the framework of Company policies and regulations; third

they cannot explain to individuals. Disclosure of the secrets of our Company to anyone other than the authorities expressly authorized by law in this regard is considered as a violation of our ethical principles.

The ownership of the internal regulatory documents and information in the form of analyzes, plans and all kinds of undisclosed or disclosed information obtained for the Company and the Company's financial data, services produced, capacity reports, computer software, expenses, business plans, customer, supplier names, working and marketing methods, announcements, regulations and instructions belong to the Company. This information may not be disclosed to non-relevant persons.

11.3- Protection of Confidential Information

Necessary measures are taken to ensure the confidentiality of the company's information, to store it and not to reveal it.

• Every evening the tables are gathered and any confidential documents are locked, the keys are stored in a safe place.
• Passwords and user codes are kept confidential and not disclosed to anyone.
• No information other than business and legal obligation notifications is copied to floppy disks and similar tools.
• Persons who are not employees of the Company are not allowed to access the Company's information network or to perform transactions on the Company's computers.

1. Implementation of Legal Rights ofEmployees:

The Company recognizes labor rights arising from the law as an integral part of human rights. The Company carries out activities in accordance with all legal rights of employees, their right to honor when successful results are achieved, stands against discrimination, forced labor and mobbing, and supports the participation of employees in decisions made for the development of the Company.

The company implements personnel development programs for employees, including training and professional development, social packages, motivation methods, working and rest conditions.

The company supports practices that strengthen staff engagement, increase discipline, productivity, and work traditions within the team.

1. In-HouseCulture:
   1. Personal relationships within the company:

All employees have the right to work in an environment of respect and understanding. Relations between the employees of the company should be based on the principles of mutual respect, obedience and loyalty in the context of superior-subordinate relations. The dialogue between the employees should be in such a way as not to break the honor and dignity of the other person.

1. Relations of the Company with the companies with which it has businessrelations:

Company employees are obliged to maintain maximum objectivity and impartiality in their relations with other companies and should make every effort to carry out these relations within the framework of the principles of justice, mutual respect, moral codes of conduct and legislation of the Republic of Turkey.

Employees of the Company may not store, alter or misuse any information for personal benefit through the Company or through other companies with which the Company has a relationship.

14- Compliance with Legal and Company Policies and Regulations

The first priority of Egem Metal employees is to comply with legal regulations and Company policies and regulations and to avoid incidents that may pose risks. Our employees never abuse their duties and do not allow them to be abused. Misconduct; is to use one's authority and responsibility for one's own benefit and thus harm the Company and our business partners.

Company employees may not directly or indirectly participate in disgraceful crimes such as theft, forgery, pickpocketing, nor shall they allow others to do so.

All Company employees, if they witness behaviors contrary to our code of ethics, should notify a senior manager and/or the e-mail address specified in the ethical principles via message.

15- APPLICATION OF ETHICAL RULES

Those who violate the Egem Metal code of ethics and codes of practice may face disciplinary sanctions up to the termination of their employment contracts.

All our employees should adopt a code of ethical behavior and should not act contrary to these rules. In all activities carried out and in the decisions taken, compliance with the Egem Metal code of ethical conduct should be questioned. In case of hesitation in compliance with the ethical code of conduct, the following communication channels should be consulted. Confidentiality is essential in applications.

• Phone: 0 232-252 60 60
• E-mail : info@egemmetal.com
• Address : Egem Metal Profil Ve Nak. Work. Hr. San. Ve Tic. Ltd. Sti.
  • Fatih Mahallesi 1178 Sokak No:9 Sarnıç Gaziemir İZMİR