KDÇ Policies Manual

EYS-PL-010
Objective
Human Resources Policy. The most valuable resource raising our company to an esteemed and effective status among the leading and exemplary companies in the world steel sector is the manpower which is sincerely faithful to his/her company and which has high qualification. Human Rights Policy. Our company displays sensitivity regarding the implementation in the direction of fundamental principles such as human rights, rights to work and social justice.
Anti-bribery and anti-corruption Policy. Loyalty to ethical principles, transparency and zero tolerance to the corruption in all of our business processes and relationships are our values with priority.

Scope
The policies in this manual cover the Kaptan Demir Çelik Endüstrisi ve Ticaret A.Ş.

Responsibility
The Integrated Systems Management Representative is responsible for the preparation, review, revision and publication of this manual and the Executive Committee Member is responsible for the approval of it with regard to competency prior to publication.

Human Resources Policy
The aim of this policy is to ensure utilization of the human resources efficiently with a view to becoming a customer-focused global company continuously sustain its leading status in the Turkish industry increasing its capacity which meets the expectations of its stakeholders, attaches importance to the employees ,open to change and a leader in its territory, efficiently uses its resources and empowered by the creativity of its employees. Objective of our Human Resources Policy is to realize the studies of planning, selection, recruitment in the service units, implementation of the human resources that will ensure the effective and efficient execution of the work in our company, determining and meeting the training needs, determining the competencies, performance management, carrying out the career planning studies in accordance with scientific methods. The right person for the right job, the right job for the right person policy is to be ensure at every level, and to bring all our employees to a common consciousness and responsibility by constantly improving the organizational structure that can adapt promptly to changes and development.

Human Rights Policy
Our company is sensitive regarding the application of the requirements of international agreements such as the International Labor Organization and the UN Declaration of Human Rights. Our country is an interested party in the direction of fundamental principles such as human rights, rights to the business, and social justice. Our company commits to fighting for equal opportunity and to fight against discrimination, disadvantages, harassment, and threat. Kaptan prohibits all kinds of discrimination against and among the employees and their managers and makes all of its evaluations independent of differences with regard to gender, mental-physical disability, pregnancy, maternity, age, race, religion, language, sect, belief, culture, and social class. Through the transparent channels of communication presented for its employees in order to receive their suggestions and opinions, the Human Resources Management encourages the creativity of the employees and their participation in the business processes. Human Resources Management supports the personal and occupational development of our employees through continuous feedback and training in terms of increasing motivation and having a corporate identity. Discipline will be taken against anyone who uses derogatory language or acts with the intent to harm someone's reputation or an institution, abuse someone's legal rights, or acts in illegal activity that goes against our company's moral and ethical standards. In all of our processes, our company commits that it will not permit any expression or act supporting slavery or human trafficking. Kaptan will provide equal opportunities for the welfare of its employees, fair treatment, recruitment, training, promotion, job description, freedom of association, and compliance with labor legislation. Our employees are responsible for adopting and applying the stated principles within the framework of trust and integrity in their business relations with their colleagues and other business relations.

Statement of the Modern Slavery Act
This statement complies with the reporting requirements of Article 54 of the UK Modern Slavery Act 2015 by Captain Iron and Steel End. ve Tic. Inc. made by Our firm is committed to respecting human rights and categorically rejecting modern slavery and human trafficking. We see our commitment to the Modern Slavery Act as part of our sustainability strategy and place it at the center of our business ethics. We are constantly working to understand and eliminate the risks in modern slavery and human trafficking. In this context, we adopt a continuous improvement approach in order to determine our commitments and developments. Our company also carefully monitors our supply chain regarding modern slavery and human trafficking and is meticulously reviewed during the Management Review Meeting (YGG) every year. The Supplier Code of Ethics and commitments require all our suppliers to exercise the same care in dealing with issues such as modern slavery and human trafficking. We expect all parties with whom we cooperate to respect human rights and to approach modern slavery with zero tolerance. Our company will continue to maintain its determination in the fight against modern slavery and human trafficking and to share the developments in this field regularly.

Anti-Bribery and Anti-Corruption Policy
Our anti-bribery and anti-corruption policy prohibits unethical attitudes and acts such as bribery and the legal constituting of a crime. We aim to ensure compliance with the highest ethical standards and anti-bribery laws which may be applied by all employees in our company. Depending on integrity and transparency which are among our fundamental priorities of us, regarding our employees and stakeholders, we have an attitude of no tolerance for all acts of corruption. We commit that any activities such as offering or requesting a bribe, accepting any gift, reward, advantage, undue priority or incentive, and the like cannot be accepted on the part of our employees and the stakeholders with whom we are in a business relationship. In case of any behavior other than the ethical and moral values to which our company attaches importance sensitively, a detailed and comprehensive investigation will be realized and the commencement of dismissal and legal procedure will be ensured according to the disciplinary procedures of our company. The principles defined in this policy from our company's commitment to integrity and sustainable business. These principles and commitments demand that all decisions comply with the principles of integrity, transparency, and accountability, and act in the culture of compliance with the awareness that bribery and corruption are not acceptable for any reason.