Anti-Bribery and Corruption Instructions

Anti-Bribery and Corruption Instructions

1. PURPOSE

The purpose of this directive is to define anti-bribery and anti-corruption policies and behaviors, to determine the position of Dinarsu in cases of bribery and corruption, to provide information and guidance in this fight.



2. FIELD OF APPLICATION

It includes all Dinarsu employees, the companies and employees we receive products and services, subcontractors, our business partners, suppliers, agencies and agencies, and all persons and organizations serving for or on behalf of Dinarsu.




       3. DEFINITIONS


Corruption: The direct or indirect abuse of the powers held in the current position and the attempt to make a profit in this way.


Bribery: The provision, offer or promise of interest, directly or through intermediaries, for the purpose of making, having, doing, not performing, accelerating, slowing down a work related to his / her job; request or acceptance; to act in violation of the requirements of the task by means of mediation such as the other person within the framework of an agreement with him or the party requesting it, or because of this relationship is to benefit someone else.

Bribery and corruption can take place in many different ways.


Some examples:

    Cash payments,
    Commission
    Gifts and entertainment that do not comply with the principles of business ethics
    Inappropriate political and other donations
    Other interests


4. RESPONSIBILITIES


The implementation and updating of the Anti-Bribery and Anti-Corruption Policy is the authority, duty and responsibility of the Disciplinary Committee within the knowledge of the Board of Directors. In addition, all Dinarsu employees are responsible for complying with the policies set by the Board of Directors, working in compliance with the relevant legal regulations and Dinarsu practices and informing the Disciplinary Committee in case of any behavior, activity or practice contrary to this policy. Dinarsu appoints top-level employees with responsibility for compliance.

5. APPLICATION



    Anti-Bribery and Anti-Corruption Policy

Being consistent, fair and honest are the most important values ​​for Dinarsu. It is Dinarsu's general policy to conduct business in ethical standards and to comply with laws.



    Bribery and Corruption

Dinarsu faces all kinds of bribery and corruption and shows zero tolerance.

Business relations with third parties who wish to do business with Dinarsu through bribery or corruption should not be maintained.



    Gift

A gift is a product that does not require financial payment and is usually given as a thank-you or commercial courtesy by persons or customers who are in business relationships. Any gift offered or given by Dinarsu to third parties must be publicly, in good faith and unconditionally offered.

Other than symbolic gifts of high material value, gifts should never be accepted. In addition, even if it is within this scope, the acceptance of gifts should not be frequent and the acceptor should notify the HR and senior management of the company through the first supervisor.

It is acceptable to give or receive corporate promotions, consumables and the like, unless you make a request for the gift and it does not appear to or does affect your impartiality and decisions.

No proposals are made in order to obtain or retain any value or benefit to any benefit or advantage as a gifting party, and that may influence, compel, or compromise the supplier employee's decision.

The gift should be allowed under the principles of the business unit and country of the supplier employee, all gifts and meals should be in accordance with the relevant laws, and should not violate the principles of the gift giving and / or the recipient and be consistent with local customs and practices.

    Facilitation Payments

Facilitation payments are not offered to individuals or organizations covered by this Policy to secure or expedite a routine transaction or process (obtaining permits and licenses, obtaining documents, etc.) with government agencies.

    treat

If the main purpose is business-related and your participation covers ordinary, traditional and business subjects, institutional hospitality such as business meals, events, social activities or social meetings is acceptable.

    Charitable Donations

Every charitable contribution and sponsorship must be made in an open and transparent manner. Before any donations or sponsorships are made, all details are subject to management approval to reduce the risk of being accepted as bribery and corruption activity or considered to be a bribe.

Record Keeping and Reporting

Dinarsu accounting and registration system has to comply with the issues that are regulated by legal regulations. According to this;

All accounts, invoices and documents relating to relations with third parties (customers, suppliers, etc.) are recorded and maintained in a reliable, complete, accurate and accurate manner,

There should be no distortion of the accounting or similar commercial records of any transaction and the facts should not be distorted.

    Education and Communication

Anti-Bribery and Anti-Corruption Policy was announced to Dinarsu employees.

Since it is important to raise the awareness of employees, Human Resources, Administrative Affairs, Financial Affairs, Law and Accounting together design training programs in which all employees must attend.

    Notification of Policy Violations

If an employee or a person acting on behalf of Dinarsu is of the opinion or suspicion that the work is contrary to this policy, it should be referred to the Disciplinary Committee.

The company or business partners with products and services should also regularly remind their employees about the Code of Ethics and encourage them to notify them if they encounter such situations.

If a situation arises that violates the anti-bribery and anti-corruption policy and / or code of conduct, the contact person (or a member of the supplier's management) of the contact is informed.

        Policy Violations, Observation and Investigation
The effectiveness of this policy is monitored and examined regularly and reported to the Dinarsu Board of Directors about its suitability, adequacy and effectiveness. Any improvement determined by the Board of Directors is applied as soon as possible. Internal audit systems and procedures are reviewed to ensure their effectiveness in combating bribery and corruption.
Employees are free to comment on this policy and make suggestions for improvement. Comments, suggestions and questions are directed to the senior management. In cases where the policy is or may be contrary to the policy, the subject is examined by the Disciplinary Committee and necessary sanctions are applied in case of inappropriate behavior.