Code of Ethics

ERKUNT Industry Inc. undertakes to act in accordance with all the processes, rules and regulations defined by laws and to abide fully by business ethics and ethical principles as stated in this ERKUNT Code of Ethics Principles and Applications document, while performing its business.

The ERKUNT code of ethics described in this document covers all ERKUNT employees, board members, suppliers, contractors, employees by proxy, in short, all parties involved and all parties are obliged to abide by the ERKUNT code of ethics.

They are among the fundamental duties and responsibilities of the mid-level and senior managers of ERKUNT to ensure that ERKUNT codes of ethics are communicated to all employees, to ensure that employees put particular emphasis on these rules, and to endeavor and show leadership to comply with these rules.

On the other hand, identifying and preventing the risks of bribery and corruption in compliance with legal regulations, ethical and professional principles and universal rules are an inseparable part of the ERKUNT code of ethics and employees and business partners are obliged to comply with this policy.

ERKUNT and Internal Contact

ERKUNT values its employees and respects employee rights. It seeks qualification as the sole measure in recruitment and employment and ensures equality of opportunity without discrimination. ERKUNT provides equal opportunities and opportunities for the training, orientation and development of employees and ensures the continuity of working peace.ERKUNT never permits harassment in the workplace and does not disclose any personal information about the employees to third parties without the permission and knowledge of the employee, except for legal obligation. It respects human rights, constitutional organization and collective labor agreement. ERKUNT does not employ child labor and does not acknowledge to employ.

ERKUNT and External Contact

ERKUNT’s external contacts with second and third-parties are guided by the following basic principles:

• Benefit from criticism and recommendations, establishing an open communication with parties,
• Ensuring the continuation of a positive relationship with the parties,
• Acting in comply with the rules of law in all its activities, as well as international agreements, policies and working principles subject to the Republic of Turkey,
• Base on the agreements with other entities and organizations to be clear and understandable in accordance with the laws and ethical rules,
• Preventing any employee from undertaking any transaction to make ERKUNT a commitmentexcept for those authorized in accordance with the principles and limits specified in the circular of signature or the relevant special authorization document,
• Creating value, meeting the demands and requirements at the highest level, providing quality products and services, followingconsistent policiesfor customers, creating a long-term environment of confidence in relations with customers,
• Creating mutual value in business relations with suppliers,
• Carrying out communication with suppliers in an open, direct and correct manner,
• Performing supplier selection with objective criteria,
• Complying with the comprehensible confidentiality and work safety rules claimed by the supplier in supplier relations,
• Ensuring nonfulfillment to make agreements and harmonized behaviors under no circumstances with competitors or other entities or organizations directly or indirectly, for the purpose of preventing, disrupting or restricting the competition, which may or may have the effect on, except for the limits allowed by the legislations, (In this aspect,exceptions granted to ERKUNT within the framework of the law and the relevant legislation are reserved.)
• Ensuring not to abuse this dominant position when it is dominant in a particular market, alone or along with other enterprises,
• Ensuringnot to negotiate and exchange information with competitors to determine market and / or competition conditions together,
• Refraining from any kind of negotiation and transactions that may be considered contrary to the ethical rules stated in this document in private or professional meetings and interviews where the company is represented,
• Aiming excellence in world-wide production processes and customer satisfaction,
• Updating the quality management system according to the developing production technology and customer expectations and giving customer-oriented responses,
• Continuous improvement in quality level of products and services, and increase in the level of competition,
• Maintaining the processes constantlyeffectivein order to meet the quality and cost objectives and carrying out studies to increase productivity,
• ERKUNT aims the following principles: To prevent environmental pollution that may arise from activities, to comply with national and international legislations and other requirements regarding environmental aspects and energy consumption, to ensure environmentally friendly production with efficient management of inputs, natural resources based on the principle of sustainable development, to evaluate electric energy from design to overall process, which is the biggest portion of the total energy consumption, to increase energy performance by taking energy efficiency in to consideration during new machinery and equipment investments, to reduce waste primarily at source and to prevent environmental pollution by following technological trends,to review environmental management system periodically by setting aims and goals intended for processes in order to continuously improve the system and providing all the means necessary to perform them and ensure an open and continuously improving company culture by training our personnel, suppliers and contractors based on our commitment for social responsibilities.

Code of Ethical Work Required by Employees

Expectations from ERKUNT employees are listed below:

• Everlasting abiding by the rules, acting in accordance with basic moral and human values while performing its duties, being fair, well-intentioned and understanding in order to create value in all relations,
• Acquiring illegally from none of entities and organizations under any circumstances, receiving and / or payingnone of bribes or facilitation payments,
• Acting in accordance with the relevant ethical rules and all application principles that support these rules and refraining from behaviors and attitudes in business and private lifethat may damage ERKUNT’s reputation,
• Unless declaredly authorized,engaging in none of behavior, declaration or correspondence that will leave the company under a commitment,
• Acting in a way that none would disturb and / or harm other employees, not disturbing business adaptation,
• Put emphasis onall tangible and intangible assets of the company, including information and information systems and protecting them against possible loss, damage, misuse, abuse, theft and sabotage,
• Usingno working time and company resources directly and indirectly for personal interest and / or political activity and interest,
• Acting in the awareness that earning income by an employee, working and taking a position aside from ERKUNT in the subjects that are within the occupation or expertise of that employee, is subject to ERKUNT’s approval.

Intellectual Property Rights protection is guided by the following principles:

• Acting in the awareness that ERKUNT is the owner of all intellectual property rights that ERKUNT employees have created during their work in ERKUNT and acting responsively against the infringement of these rights.
• Ensuring on a timely manner initiation and completion of legal proceedings in order to guarantee the intellectual property rights of newly developed products, processes and software.
• Refraining from unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual property rights of other companies.

Information Management is ensured by the following principles:

• Ensuring that all legal records are kept properly,
• Ensuring that all information and document requests from public enterprises are responded by the relevant departments in the nature of work,
• Responding to none of the requests for information from third parties that is considered in the confidential category without the approval of the senior management,
• Awareness that all documents used by the employees related to the work belong to ERKUNT, retention or disposal of the documents in accordance with the ERKUNT procedures,

Asset Management necessitates the following principles:

Put emphasis on protection and use of the Company’s assets effectively, taking all precautions to prevent theft or damage, and to be aware that the Company’s employees are responsible for the assets that are embezzled on them and the damages caused by them during their use,
Security and Crisis Management is involved closely in the following principles:

• Taking necessary precautions for protection of company employees, information and information systems, factories and administrative facilities against possible terror, natural disaster and malevolent initiatives,
• Making the necessary crisis planning related to the emergency crisis management to be created, in case of terrorism, natural disaster and so on, ensuring the continuity of the work with minimum loss during the crisis with that attitude.

Privacy necessitates the following principles:

Acting in the awareness that ERKUNT’s financial and trade secrets, information that will undermine its competitiveness, personnel rights and information, agreements with business partners are within the “confidentiality” and ensuring their protection and confidentiality,

Sharing none of the information and documents learned for business purposes with unauthorized entities and authorities inside and outside the organization for whatever purpose and using none of them for speculative purposes,

Conflict of interest includes any kind of personal interest or pecuniary advantage or personal gain that may affect the impartial performance on duties of the employees and that is provided to them, their relatives, friends or related entities or organizations. According to that;

• Providing none of unfair interests in favor of himself, his relatives or third parties, taking advantage of the title and authority,
• Ensuring that personal investments or other activities apart from business do not interfere with the time and paying attention of their current work and avoiding such situations that prevent them from focusing on the main tasks,
• Informing to immediate supervisor, in case,the entity as a first-degree decision-maker in the position of the customer or supplier in the same business is the first-degree relative of the employee, and in case that first-degree relatives in a commercial relationship with other organization have a share or financial interest, information to the immediate supervisor is required.

Participation in organizations and activitiesin a business relationshipthat are or may be perceived as effective in the decision-making process, carried out by entities or institutions or potential ones is required by ERKUNT’s approval. If there are any support activities carried out by ERKUNT (such as sponsorship, scholarship), it is managed institutionally. Any employee who has not been assigned shall not operate on behalf of ERKUNT on these and similar issues.

In the conduct of relations with private or public persons and organizations wishing to establish or maintain business relations with ERKUNT; accepting and offering none of gift,apart from promotional materials, that may be perceived as irregularity and that may cause or may be perceived as an addiction, requesting none of discount and benefit from suppliers, customers, third parties that may be perceived as inappropriate, not proposing to third parties, not accepting in case of proposal are a must.

Doing business with ERKUNT as a seller, contractor, consultant or similar as a partner to a company or by establishing a company after resigning from ERKUNT,must be considered as a very important issue that may perceived as negative.In case of an improper situation, no commercial relationship must be established with the person concerned.In order to prevent negative perceptions except in exceptional circumstances, the establishment of such commercial relations with the former employee must be prevented.It shall not be certainly attempt and considered to be a crime and also being aware that using any kind of confidential information belonging to the company or giving it to third parties in order to obtain any commercial interest.

Worker’s Health and Safety

For all the activities and facilities; it is essential to prevent occupational diseases, occupational accidents, to comply with national and international legislations and other requirements regardingoccupational safety risks,to review occupational health and safety management system periodically by setting aims and goals intended for processes in order to continuously improve the system and providing all the means necessary to perform them and ensure an open and continuously improving company culture by training our personnel, suppliers and contractors based on our commitment for social responsibilities and cooperation.

Prohibitionof Political Activity

ERKUNT does not donate to political parties, politicians or political candidates. Demonstration, propaganda and similar activities within the workplaces shall not be permitted in these matters.Company resources (such as vehicles, computers, e-mail) shall not be allocated to political activities.

Ethical Codeof ConductApplication Principles

Report Obligation for Violations

If employees find out or suspect that the company’s laws, regulations or rules are violated, they are obliged to inform to their immediate supervisor or e-mail to etik.politika@erkunt.com.tr , according to circumstance.

Notification made by the employee in a way that negatively affects the peace or work relations in the workplace shall be prevented from being disclosed to third parties.

The notification mechanism must be in accordance with the benefit of the company.

It is very important that the employee made notification is free from intentions such as gossiping about the employee being notified or attempting to negatively affect his career. From this point of view, confidentiality, objectivity and compliance with ethical rules are extremely critical issues in the notification and investigation process. Both the employee who notified and the entity managing the relevant process shall pay close attention to this issue.

In case of deliberate notifications detectionconsidered as lie and / or slander, it is interpreted as a violation of ethical rules.

Disciplinary Practice

If there is an intentional misconduct after violations of the code of conduct; sanctionsup to dismissal (in accordance with the relevant articles of the labor law), enforcement and, in case of need, legal action may be initiated. The useful work done in the past by an employee who purposefully provides unfair advantage shall not be partially or completely reason of excusing.

In case of no abuse or negligence arising from carelessness or ignorance, verbal or written warningsare givenin accordance with the effect of the incident.

Execution and Audit

The operation of the ethical rules described above that shall be complied with in all activities is conducted by ERKUNT SANAYIA.S. management and disciplinary board. The Board of Directors and the Disciplinary Board may appoint entity and / or entities regarding their activities and ensure that the necessary precautions are taken.

ERKUNT practices and sanctions regarding company policies are defined in service contracts, regulations, related circular letters and procedures.