Iron and Steel - Sustainability - Policies

Employee Code of Ethics

Employee Code of Ethics

"The Employee Code of Ethics" encompasses the fundamental behavioral principles of our employees. In situations where job procedures, instructions, standards, laws, and regulations may not provide guidance on all attitudes and behaviors, our "Employee Code of Ethics," based on our company values, applies.

What is Ethics?
Ethics refers to the set of accepted norms and rules within a society that regulate people's behavior and their relationships with each other. Ethics, in a universal sense, encompasses a set of universally accepted moral values. In short, ethics is the philosophy of morality.

The Importance of Ethics
Having ethical values in place within an organization and effectively practicing ethical management carries various benefits. The ethical functioning of an organization is directly related to the common goal of profitability, which is the ultimate aim of all commercial endeavors. Particularly in recent years, consumer awareness and sensitivity, as well as employee education and expectations, have increased. In order to maintain their existence in the long term, organizations are required to be responsible and ethical entities that consider consumers, society, the environment, and their employees.

Business Ethics
Business ethics encompasses a set of principles developed to guide behavior in the business world and represents the moral and ethical belief system that guides the values, behaviors, and decisions of an organizational entity and its individuals. Knowing what is right and what is wrong and acting in accordance with what is right is a matter directly relevant to decision-makers within a business (managers, partners, etc.) and all employees in the organization. Kaptan closely monitors global developments related to social values and norms concerning sustainable business practices and places importance on continuous self-renewal, recognizing that these developments are subject to change.

Not Seeking Personal Gain
As a requirement of sustainability, we maintain a zero-tolerance policy against corruption and bribery. Facilitating payments to public institutions or private sector entities is not permitted. Our employees do not seek personal gain for themselves, their families, or their close associates from individuals or organizations they engage with in the course of their duties. They do not engage in financially motivated business activities. They do not use the name and influence of our company for personal benefit, nor do they compete with the company. In cases of potential conflicts of interest, they ensure that ethical rules come into play and that the interests of relevant parties are safeguarded through legal and ethical means. In situations of doubt, they consult with their managers or the Human Resources Department. The fundamental principle is that our employees do not accept any object or benefit, whether it has economic value or not, directly or indirectly, which could affect or have the potential to affect their impartiality, performance, decisions, or duties. Books, magazines, articles, calendars, or similar items, awards or gifts won in public competitions, campaigns, or events, commemorative gifts given at public conferences, symposiums, forums, panels, meals, receptions, or similar events, and promotional arts and crafts products distributed to everyone and having symbolic value can be accepted as gifts as long as they do not contradict the fundamental principle mentioned above.

Truth and Honesty
Truth and Honesty All employees embrace truth and honesty as an indispensable value in all their business relationships with other stakeholders and act accordingly. We emphasize the importance of conducting ourselves in a manner that earns the trust of all stakeholders to maintain our integrity and reputation. We consider it a fundamental value to prioritize truth and honesty in all processes undertaken to uphold the highest standards of behavior and in all relationships we establish.

We support transparent and open communication in our relationships with stakeholders and third parties. We ensure that decisions made within our internal processes are jointly monitored and implemented by the Board of Directors, that activities are conducted in collaboration with members within a framework of respect, and that authorized individuals are consistently accessible. In our stakeholder relationships and in the adoption of a corporate ethical culture, we fulfill our responsibility to society through transparent reporting. As Kaptan, we aim not only to be a company but also a source of strength and motivation that emphasizes the importance of sustainability and ethical values with our reports.

Information that could create a competitive disadvantage, personnel records, confidentiality agreements with third parties, trade secrets, and any as-yet undisclosed financial or other information are considered confidential. Our employees who, by virtue of their position or for any reason, have access to confidential information related to our operations, protect such information and use it solely for our purposes. They do not use it for any commercial or personal gain. Additionally, they exercise care in safeguarding their confidential and private information. During their employment or upon departure from the company for any reason, employees who possess any form of confidential information or documents, either by virtue of their position or for any reason, do not disclose or provide such information to external parties without proper authorization. They only share it within the designated authorities. Under the terms of confidentiality agreements, information provided by suppliers, customers, and other business partners is not used for purposes other than the intended ones and is not shared with unauthorized third parties.

Conflict of Interest
KAPTAN employees aim to avoid conflicts of interest. They should not seek personal gain, either directly or indirectly, through their current position by engaging in business relationships with individuals and organizations that involve personal interests for themselves, their families, or close associates. Engaging in additional financial-based business activities outside of KAPTAN is not allowed. Using the name, power, and identity of KAPTAN for personal gain should be avoided. In the event of a potential conflict of interest, if there is a belief that the interests of the relevant parties can be safely protected through legal and ethical means, employees should consult with the relevant Company Manager, the Human Resources Department, and the Ethics Committee when in doubt.

Fair Competition
We believe in fair, free, and open competition. We achieve our competitive advantage not through unethical or illegal business practices but through the quality of our products. We work towards being industry leaders and maintaining the highest level of customer satisfaction through innovation and continuous improvement. Our goal is to add value to our customers in a competitive environment and earn their trust. Fair competition is not only an ethical rule for KAPTAN but also a strategy adopted for the long-term success and sustainable growth of our company.

Time Management
It is essential for KAPTAN employees to use their working hours efficiently and not allocate work hours to personal matters. Managers should not assign their employees to handle personal tasks. Ensuring the effectiveness of allocated time for meetings is the responsibility of the meeting organizer, and all participants are required to come prepared to the meeting. The start and end times for the allocated time for meetings must be adhered to by all participants. Accepting personal visitors during working hours is generally not allowed, and in exceptional cases, meetings with external visitors should not exceed 10-15 minutes. Personal Matters: Employees should not engage in personal matters during working hours and should remain focused on their tasks. Meeting Efficiency: Meetings should be managed efficiently, participants should come prepared, and scheduled times should be adhered to. Assignments: Employees should not be assigned to handle personal tasks and should focus solely on their duties within the company. Prioritization and Planning: Employees should enhance their prioritization and planning skills to manage their time effectively. Intra-office Communication: Fast and effective communication channels should be used, unnecessary email traffic should be reduced, and important information should be communicated directly. These rules are fundamental in ensuring that our employees manage their time effectively and increase their productivity.

Outside Business Activities and Taking on Roles
Employees are prohibited from engaging in activities that would require them to be classified as traders, artisans, or independent professionals. They cannot become partners in other companies. They cannot take on paid or unpaid roles in any company or commercial enterprise, except for positions in subsidiary companies and affiliated partnerships. Taking on roles in organizations related to the company's activities or those with social purposes, such as cooperatives, professional associations, unions, professional and social-purpose associations, foundations, federations, and confederations, requires approval from the Board of Directors. For employees with expertise, teaching at professional conferences, universities, and vocational schools is subject to approval by the Board of Directors, provided that it does not interfere with their job responsibilities. Our employees are not allowed to engage in activities classified as trading, artisanal work, or independent professional work. Additionally, they do not have the opportunity to become partners in other companies or to take on roles, whether paid or unpaid, in commercial enterprises. In other words, an individual employed by our company cannot work for another commercial organization or collaborate with them. However, there are some exceptional cases. For example, they can engage in activities and take on roles related to organizations such as political parties, non-governmental organizations (NGOs), cooperatives, professional associations, unions, professional and social-purpose associations, foundations, federations, and confederations, but only if these activities are not in conflict with their responsibilities at the company.

Our company strictly prohibits discrimination based on belief or disbelief, language, race, age, health status, gender, and marital status, among other factors. Such forms of discrimination are entirely outside the scope of our workplace policies and may be subject to legal sanctions. In this context, any public speech that includes hate speech targeting a specific group or promotes violence against individuals in that group is not allowed. Our employees have the right to file a complaint with the Human Resources Directorate if they experience any form of discrimination. Kaptan takes such complaints seriously and takes the necessary steps to protect the rights of employees. Our aim is to ensure that every employee works in an environment based on respect, equality, and justice. Therefore, we are committed to combating discrimination and diligently enforcing our rules against discrimination to protect our employees' rights and foster a workplace culture that aligns with our values.

Brand Protection
The KAPTAN brand is our most important asset, upon which we draw strength in all our activities. Consistently safeguarding and enhancing the strong reputation of our brand in line with our marketing and communication principles is our top priority. Our employees are responsible for carrying out their duties in accordance with the principles of preserving and elevating our brand. We acknowledge that personal social media accounts are the private spaces of individuals and respect their sharing preferences. However, we expect that social media accounts be used with personal email addresses outside of company-related emails. We also expect our employees to refrain from sharing content that may cause disputes, uncertainties, or share content that represents the Company; and not to engage in sharing information and photos that would violate privacy rules. Preserving and enhancing the strong reputation of the KAPTAN brand is at the core of our communication principles. Our employees are obliged to carry out their duties in accordance with the principles of preserving and enhancing the reputation of our brand. We understand that social media is a platform for personal space, and we respect everyone's preferences. However, we expect our employees not to associate their social media accounts with our Company except for personal emails, to avoid sharing content that represents the Company on social media, to stay away from sharing content that may cause disputes or uncertainties, and to refrain from sharing information and photos that would violate our privacy rules.

Media Relations
Providing statements, giving interviews to any media organization, participating as a speaker in seminars, conferences, and similar events, and determining whether compensation will be received for such activities are subject to the approval of the Board of Directors. Under no circumstances can personal gain be obtained from these activities.

My Responsibilities
As one of the largest industrial organizations in our country: KAPTAN complies fully with legal obligations and also fulfills its responsibilities towards all stakeholders and competitors. Our employees act with the awareness of these responsibilities in mind.

My Legal Responsibilities
While conducting all business processes and relationships, our employees adhere to our country's laws and, where necessary, international legal rules, approach institutions and organizations without any expectation of benefit, and provide accurate, complete, and understandable information to institutions and organizations on a timely basis.

My Responsibilities Towards Our Customers
In line with our principle of "Customer satisfaction comes first," our employees work with a focus on customer satisfaction, being sensitive to their needs and requests, anticipating possible events, and taking a proactive stance. They provide their services to customers in a timely and as-promised manner and communicate with them in a respectful, fair, and polite manner.

My Responsibilities Towards My Colleagues
Starting from the slogan "Our most valuable asset is our employee," all employees are treated equally. They provide a working environment in compliance with occupational health and safety rules. They plan and implement training programs aimed at providing employees with the necessary knowledge, skills, attitudes, and behaviors required by the nature of their work to improve job satisfaction and achieve greater success in the workplace. They consider the balance between their employees' work and personal lives important. They make efforts for individual development and support their participation in appropriate social and community activities with a sense of social responsibility.

Carry out their responsibilities towards their colleagues within the framework of these principles, with mutual trust, respect, and courtesy, in communication and collaboration. Support each other with their knowledge, skills, and experiences when working or encountering a problem.

My Responsibilities Towards Our Suppliers
In collaborations, they give importance to creating the highest level of value for both sides, determining mutual needs, and meeting those needs. Based on the principle "All suppliers are natural members of our team," our employees treat all suppliers honestly, fairly, and respectfully, fulfill their obligations on time, and handle the confidential information and documents of suppliers and business partners with due care and sensitivity.

My Responsibilities Towards Our Shareholders
Our employees aim for sustainable profitability in line with the goal of "Creating value for our shareholders." They act within the framework of financial discipline and transparency, manage the company's resources and assets efficiently and with a sense of economy.

My Responsibilities Towards Our Competitors
Our employees avoid unfair competition. They compete in areas that are legal and ethical, and instill this vision in society. In this context, they support efforts aimed at the transformation of society into a competitive structure.

My Responsibilities Towards Society and the Environment
Our company, which defines work safety as a top priority and environmental protection as a mission with the motto "Respect for people and the environment," has adopted a basic goal of acting responsibly towards all social stakeholders with accountability, reliability, openness, and its values. From raw material use to technology, from production activities to management style, our company has undertaken an environmental responsibility based on the principle of voluntarily undertaking initiatives to continuously improve environmental performance beyond legal requirements. Our employees conduct all activities in line with this consciousness. They participate in social organizations and services in line with their social awareness and strive to be exemplary citizens.

All KAPTAN employees are obliged to comply with the ethical rules stated in this handbook, and individuals or situations considered to act contrary to ethical rules should first seek reconciliation and a solution by discussing the issue with their immediate superiors in the department they are affiliated with. This way, a communication and resolution process regarding ethical issues is initiated among employees. Additionally, our employees can report ethical rule violations via email while keeping their identity confidential. We have a Complaint Notification System for complaints, suggestions, and other feedback. This system is managed through the "request, complaint, and suggestion notification" page on our website, along with "notification boxes" within the company and the "Contact Us" section on Kaptan Port. This way, notifications are recorded, reviewed, and necessary actions are taken. The Ethics Committee evaluates the notifications, takes appropriate steps, and initiates an investigation process when necessary. Our goal is to establish an effective notification and evaluation mechanism for the detection and resolution of ethical violations. Employees who make notifications are assured that they will not suffer from a reduction in their seniority, fines, or other sanctions due to reporting violations or expressing their concerns. Confidentiality and follow-up of notifications are ensured through mutual communication with the person making the report. Those who violate ethical rules, approve such violations, or have knowledge of violations but do not report them are evaluated by internal committees and may be subject to disciplinary sanctions. This is aimed at preventing behaviors that do not comply with ethical standards and taking necessary measures.

EYS-ÇEK-020 REV1 17.07.2023