Code of Ethics and Business Conduct Regulations

The purpose of these Code of Ethics and Business Conduct Regulations is to advise, by explaining, the employees and customers of the moral values and rules of Kocaman Denizcilik and to declare that commercial activities will be continued pursuant to these norms also in the future.

Scope

The code of ethics includes the principles that our company employees must obey while performing their duties and the principles regarding the working order. The purpose of these principles is to outline the basic rules to be complied with and to prevent any disputes and conflicts of interest that may arise between employees, business associates, customers and our corporation.

Business Conduct Regulations created under the scope of Code of Ethics is valid for all Kocaman Denizcilik employees without any exception- position and seniority level makes no difference. We all have the responsibility to be knowledgeable about the contents of the Business Conduct Regulations, and one should talk to their Human Resources Manager about any issue one is not sure about. We all have to understand exactly what is expected from us as part of our positions and what the policies contained in the Business Conduct Regulations set forth for us.

Basic Principles

Managers and employees should do their part to maintain the reputation of Kocaman Denizcilik at the highest level by taking into account the basic principles in this document when conducting all kinds of relationships and business. Our employees should act on the basis of care and commitment in situations and under circumstances not covered by these rules.

Our Rules Of Business Conduct

Integrity

Integrity and honesty are our primary values in all our business processes and relationships. We act with integrity and honesty in our relations with employees and all our stakeholders.

Confidentiality

Confidential and private information includes information that may create disadvantages in terms of competition, confidential business information, financial and other information not yet disclosed to public, information on personnel’s personal rights and information within the scope of “confidentiality agreements” executed with third parties.

As employees of Kocaman Denizcilik; we take care to protect the privacy and private information of our customers, employees and other relevant persons and organizations we cooperate with. We protect confidential information regarding the activities of Affiliates and use such information only in line with the purposes of Kocaman Denizcilik; we share this information with relevant people only within the scope of specified powers.

Even when we may quit our company, we do not secretly take away with us any confidential information and/or documents regarding projects, regulations et c. that we may be in possession of at the time, as a result of and in relation with our positions

Conflict of Interest

As the employees of Kocaman Denizcilik we aim to avoid any conflict of interest. We do not gain, by making use of out position at the time, personal benefits from persons or organizations that we have a business relationship in person or through our family members or our acquaintances. We do not engage in business activities, based on an additional financial interest, with any entity other than Kocaman Denizcilik and its Affiliates. We strictly avoid using the title, power and identity of Kocaman Denizcilik in order to gain any personal benefit.

In case of a potential conflict of interest, we apply these methods when we believe that the interests of relevant parties can be safely protected through legal and ethical methods. In case we have any hesitations, we consult our manager, Human Resources Department or the Ethics Committee.

Respect for Human Rights and Legitimacy

Kocaman Denizcilik acts in accordance with the absolute and universal standards of human rights. The company accepts the United Nations Universal Declaration and the Convention on the Rights of Child. In this sense; it is forbidden to employ child labour in any department of the company.

Kocaman Denizcilik; respects laws and regulations, and enforces and abides by laws. The company as a whole, condemns any type of illegal formations and fights against all kinds of illegal formations and individuals. In case of need, we cooperate with the authorities to prevent illegal activities.

Political Activities

Kocaman Denizcilik neither supports political parties nor contributes to the funding of groups acting on account of promoting party interests or the selection of a particular candidate. Kocaman Denizcilik and its affiliates do not donate to political parties, politicians nor political candidates. Demonstration, propaganda and activities with similar objectives about such issues are not allowed within the borders of the workplace. Company resources (such as tools, computers, e-mails) cannot be allocated to activities with political purposes.

Our Responsibilities

Besides our legal responsibilities, we take care to fulfill our below listed responsibilities for our customers, employees, suppliers and business associates, competitors, society, humanity and the environment.

  • Our Legal Liabilities

    While conducting all business processes and affairs, the Company complies with the laws of our country and international legal rules where required. We approach institutions and organizations without expectation of any interest, and stand neutral and at an equal distance to civil society organizations and political parties.

  • Our Responsibilities Towards Our Customers

    As per our principle, “Our customers' satisfaction comes before anything else”, we work with a customer satisfaction oriented proactive approach and respond to our customers' needs and demands in the shortest while and in the most accurate manner. We provide our services on time and under the conditions promised by us; we approach our customers pursuant to norms of respect, honour, fairness, equality and kindness.

  • Our Responsibilities Towards The Employees

    Acting in accordance with the understanding of “Our most valuable asset is our employees”, we treat all our employees equally. We make sure that employees' personal rights are fully and accurately used. We treat our employees honestly and fairly, and guarantee a nondiscriminating, safe and healthy working environment. We make the necessary efforts for the personal development of our employees, support them in volunteering for appropriate social and common activities with social responsibility awareness, and we protect the balance between business life and private life.

    Employees fulfill their responsibilities towards their colleagues within the scope of these principles, in the framework of mutual trust, respect and kindness towards each other through communication and cooperation. They support each other with their knowledge, skills and experience when performing their duties or when they encounter a problem.

  • Our Responsibilities Towards Our Suppliers

    We attach importance to creating the highest level of value for both parties and determining mutual needs and meeting the same as we work with our suppliers. We approach all our suppliers with integrity, fairness and respect, fulfill our obligations in a timely manner, and show duly care and sensitivity to confidential information and documents and protect the same.

  • Our Responsibilities Towards Our Rivals

    We compete effectively only in areas that are legal and ethical, and avoid unfair competition.

    We support efforts to ensure the competitive structure aimed to exist within the society.

  • Our Responsibilities Towards Society, Humanity and Environment

    Protection of democracy, human rights and the environment; educational supports and charity work, eliminating crime and corruption are very important to us. We act sensitively as a pioneer in social issues with the awareness of being a good citizen; and try to participate in non-governmental organizations, services for the public weal and in appropriate activities on these topics.

    Our company, which defines providing occupational safety and protecting the environment as its primary focus in its services, has adopted the principle of acting responsibly towards the society as per its values of transparency, reliability and accountability as its main objective.

  • Our Responsibilities Towards The Brand “Kocaman Denizcilik”

    Our business associates, customers and other stakeholders trust us thanks to our professional competence and integrity. We endeavour to keep this reputation at the highest level.

    We offer our services within the scope of company policies, professional standards, our undertakings and ethical rules, and we work devotedly in order to fulfill our obligations.

    We take care to provide services in areas that we believe we are and will be professionally competent, and we aim to work with customers, business associates and employees who meet the criteria of integrity and legitimacy. We do not work with those who damage the morals of the society, harm the environment and public health.

Our Policies That Underpin Business Conduct Rules

Conflict of Interest

Basic principles regarding conflicts of interest and their management are specified below.

  • Our employees may not use their positions and powers for the benefit of themselves, their families or 3rd parties in any way to gain personal and private interest.
  • Our employees may not accept direct or indirect gifts, provide benefits, and accept debts from people or companies with whom the company is in a business relationship.
  • Our employees may not give away gifts and provide benefits, that may affect other parties' impartiality, decisions and attitudes, to third parties and organizations.
  • Resources and facilities of the company may not be used to support political activities; political activities may not be carried out within the company, donations may not be made to political parties or their candidates, and political campaigns may not be supported.
  • Employees may not perform actions and behaviours against morals, laws and the discipline of Kocaman Denizcilik.

Use of Resources

Company interests are taken into account when using resources on behalf of Kocaman Denizcilik. Company assets, facilities and personnel may not be utilized outside the Company, regardless of the title and and on behalf of or for the benefit of whosoever, without any interest of the Company. The principle of “saving on any thing” is applied by all staff.

Correct use of resources in the Company's interests also requires proper use of time. During the working hours, the Company employees use the time well and do not spare time for their private issues during the working hours. Managers cannot assign employees for their personal work.

It is essential not to accept private visitors during working hours. Employees are required to complete negotiations with compulsory visitors in a reasonable time in connection with the subject of the visit and in a way that it will not hindering the workflow.

No private business relationship can be established with the Company's customers, subcontractors or suppliers and other persons and/or organizations with which the Company has commercial relations; personal debt, money and/or goods/services may not be received, and other persons and/or organizations that the Company has commercial relations with or cannot be lent goods and/or services.

The following issues are taken into consideration in relations with customers; Even if it is to the advantage of the customer, no action may be taken without informing the customer, and even if it is to the advantage of the company, customer weaknesses cannot be benefited from and profit may be pursued by providing the customer incomplete or incorrect information.

Company personnel cannot request or imply a request of gifts from other persons and/or organizations with which the Company has commercial relations; No gifts, money, cheques, property, free holidays, special discounts etc. that will put companies under obligation may not be accepted. No personal assistance or donations may be accepted from any person or organization that has a business relationship with the company. Regarding the issue, Gift Acceptance and Delivery Policy is applied.

Gift Acceptance and Delivery

It is essential that Kocaman Denizcilik and its employees do not accept gifts or benefits that may affect their impartiality, decisions and behaviour, and do not attempt to provide gifts and benefits that may create such effects to third parties and organizations. The principles of practice specified below regulate the gift exchanges that may be made with the third parties and organizations with which the Company employees have a business relationship and determine the principles to be applied in this regard.

  • Gifts That May Be Given

    It must be ensured that the gifts to be given to the parties with a business relationship comply with the rules specified in this document. The following rules have been designated concerning gifts to be given accordingly.

    The basic rule in this regard is not to give away any amount of money or easily convertible gifts. However, in accordance with our traditions and customs, gifts that our employees can give in accordance with their status and position, due to private or general celebrations (wedding, engagement, birthday, etc.), are excluded from this scope.

    The gifts given must not be intended to affect the impartiality, decision and behavior of the counterparty regarding any business, agreement, or bureaucratic procedure in which the company is involved.

  • Gifts That May Be Accepted

    Our employees may not request any personal payment or gift from the 3rd parties who do business with the company and they may not act in a way that may imply such a request.

    Our employees may not accept monetary payments in any way and amount. That includes items which are easily convertible (gift vouchers, etc.).

Protection of Confidential Information

Information is one of the most important assets that Kocaman Denizcilik will utilize to realize its vision. Therefore, it is the common responsibility of all our companies and employees to ensure the efficient use of information, sharing it correctly and ensuring the confidentiality, integrity and accessibility of the information in this process. Mutual harmony between the management systems established and the processes implemented for the management and confidentiality of information in our companies is important for the Group to achieve the highest level of benefit. Following implementation principles identifiy confidential information for the company and regulates the principles that employees must comply with regarding confidential information.

Any information pertaining to the company is subject to the principle of confidentiality and it is forbidden to transfer and trade this information to third parties. In this regard;

  • Every kind of information concerning the company and personal information about the employees and information about the customers and business associates is kept confidential.
  • Employees may not disclose confidential and non-public information about the company nor use them in favour of themselves and others.
  • Information about the customers of the company is kept confidential within the scope of personal data protection. Except for any written order issued by competent authorities, it is never delivered to third parties.
  • Company's private trade secrets, financial information, customer-employee information and all information acquired during the working period, and all other regulations and practices, and all the work done by the employees during their working hours are the property of the company. Information on third parties acquired during operations performed is also in this scope.

Creating and Maintaining a Fair Working Environment

Kocaman Denizcilik considers creating and maintaining a fair working environment for its employees as one of its top priorities. It is aimed to increase the success, improvement and commitment of the employees by creating a fair, respectful towards employees, healthy and safe working environment that complies with all relevant laws and regulations.

Following principles of practice designate the basic principles for establishing and maintaining a fair working environment in the Companies.

  • It is unacceptable to discriminate among employees within the organization on the basis of language, race, color, gender, political thought, belief, religion, sect, age, physical disability and similar reasons.
  • Private lives and personal spaces of the employees are respected.
  • A positive and harmonious working environment that supports cooperation in the company is created and by preventing conflict environments people with different beliefs, thoughts and opinions are made sure to work in harmony.
  • Even if it is recorded in accordance with the law, it is prohibited to illegally give/spread to other persons personal data or capture the same.
  • Communications between persons are not to be violated by non-parties.
  • Violation of employees' immunity in any way by the physical, sexual and/or emotional harassment in the workplace or anywhere they are at the time for the purpose of work is against the law and ethical rules and such crimes are not tolerated in any way by the Company .
  • It is ensured that workplace physical working environment and conditions are healthy and safe for all employees.

Commercial Integrity

  • Competition and Anti-Trust

    Kocaman Denizcilik takes its responsibility regarding the competition law (or anti-trust law) very seriously. No tolerance will be shown for violations of the competition law.

  • Trade Associations

    Kocaman Denizcilik employees should be especially careful when joining a trade association in order not to engage in any anti-competitive activity or create such an impression.

  • Money Laundering

    As per Kocaman Denizcilik's policy, payments from our customers in the form of cash, travel check, third party payments or money transfer are not accepted for the services supplied as per a contract. It is generally preferred to withdraw customer payments from a bank account registered in the name of the customer who was sent relevant invoice .

  • Bribery and Corruption

    Bribery is the provision or acceptance of a gift, payment or other benefit in order to gain a commercial advantage. Bribes do not necessarily have to be actually paid; it is sufficient even if it is only asked or offered. Bribery can pose a problem regardless of whether it occurs during business affairs with the private or public sector.

    Bribery or corruption is by no means acceptable and transparency is our main principle in all our business activities. In your relations with private and public sectors, you must always follow the basic rules below:

    • Never offer or make unauthorized payments;
    • Never encourage someone to do something illegal or inappropriate;
    • Always report any doubts or information about improper payments offered or received, and
    • Never offer or accept money, gifts or commissions (or anything of value) in exchange for a tender or work.
  • Facilitation Payments

    Facilitation payments are payments made to public officials (or another person) so that they can perform their duties faster or not at all. Although these payments may be in small amounts, you must not make such payments.

Employment

  • Health and Safety

    As Kocaman Denizcilik, thanks to our employees, we will be not only a good company to work and do business with, but also a company with high reputation for high standards and quality.

    Our employees are our most valuable asset. Employees are the key factor in the success of the business.

    It is the responsibility of every manager to ensure that all our employees without any exception are motivated and inspired to serve each other and our customers at the highest level.

    It is our moral obligation to protect each other, our customers and the environment by ensuring healthy and safe workplace conditions that can be safely improved at all times and minimize our environmental impact.

    Kocaman Denizcilik aims to provide a safe and secure working environment for all employees and to promote best practices within its organization. Our objective is basicly:

    • To prevent injury of any of our employees;
    • Carrying out a complete risk assessment as soon as possible when a new contract is to be executed;
    • Evaluating impacts on safety when making purchasing decisions, and
    • To ensure that every employee receives the necessary training to perform his job safely.
  • Fair Treatment and Equal Employment Opportunity

    Kocaman Denizcilik respects and values the individuality and diversity that each employee brings to the organization and aims to create an open and positive working environment wherever we operate. As regards our employees;

    • We aim to build our relationships with our employees on the basis of the dignity of the individual and fair treatment for all.
    • We aim to recruit and promote our employees on the basis of fitness for work, without making any discrimination.
    • We do not tolerate any type of discrimination or sexual, physical, mental or other kind of harassment against our employees.
    • We direct all our employees to our goals, provide them with motivation to achieve our goals and appreciate their success.
  • Working Without Harassment/Bullying

    We expect all employees to be treated fairly and respectfully. We will not tolerate acts such as harassment or bullying against our employees, suppliers, business associates or customers in the workplace.

    Please make sure to always comply with the basic rules below;

    • Don't make jokes and wits about race, ethnicity, religion, age or sexual orientation;
    • Do not distribute, disclose or keep material such as emails, cartoons, photographs which may be deemed as an insult within the working areas;
    • Do not spread malicious rumors or make use of email, voicemail, or other methods to spread humiliating and discriminatory comments; and
    • Always accept any personal information as confidential. Do not abuse such information and do not forget that: No insults, intimidating, degrading or malicious behavior will be tolerated.

    Any sort of harassment and abuse is against company policy and such behaviours will not be tolerated. If you are being bullied or harassed, or if you are aware of such a situation against someone else, please call your Department Manager or Human Resources Manager to advise them of your discomfort.

Assets of the Company

  • Confidentiality

    Employees must not disclose any confidential information about Kocaman Denizcilik or its activities outside the Group of companies, unless they have special powers in this regard.

    When confidential information is to be disclosed to another party, it should only be disclosed as subject to the terms of a written confidentiality agreement or commitment executed with the other party.

    If you need to disclose any confidential information as per instructions of any competent judicial, governmental or regulatory or supervisory authority, you must inform your legal team and obtain their approval before disclosing such information.

    Employees must not use company confidential information for their own personal advantage or for the benefit of a friend or relative of theirs.

  • Tangible Assets

    It is the responsibility of all of us to ensure that the property we use or touch as part of our business is not damaged, misused or wasted.

    Please make sure that the property you use is kept in good condition so that it can continue to be used safely and properly.

External Activities

  • Activities For Benefit Of Society and Charitable Work

    Being successful in business depends on meeting legal requirements and being sensitive to local customs and traditions that regulate business relations. The communities in which we operate (and choose our employees from) are important to us.

    Kocaman Denizcilik aims to improve its effect on the environment it operates and the communities it serves through donations and sponsorships, in a way that they will be for the benefit of all its stakeholders.

  • External Communication

    As part of our daily business affairs, we may communicate with key “stakeholders”, such as employees, business associates, customers and governments. It is very important that our communications with our stakeholders are performed pursuant to our Communication Procedure.

  • Environment

    Environmentally-conscious acts are not an industry, but an attitude and approach that represents a necessary part of all our activities. In short, it is important that everyone, regardless of their position, practise environmental responsibility in all areas under one's control.

    Besides complying with all relevant environmental legislation, Kocaman Denizcilik has also developed its own common forms of conduct to be applied in all our activities.

    In order to improve the environmental performance of our operations we cooperate closely with our customers. Basic rules you must comply with are:

    • All employees must comply with company rules and procedures concerning environmental issues;
    • Try to have the right information, training and tools required to implement responsible environmental practices;
    • Try to prevent or minimize the release of pollutants, which may emerge as a result of your work activities, into the environment;
    • Dispose of all waste materials properly and pay due attention to good waste management practices.
    • Find out which is the most environmentally friendly option for the disposal of a specific waste in your workplace.
    • Employees found to have disposed of waste materials improperly or illegally may be subject to disciplinary action;
    • All employees must take care not to perform activities that cause water waste.

Compliance With The Regulations

All employees and managers are individually responsible for complying with these Code of Ethics and Business Conduct Regulations and implementing their terms. In addition to this, the company will take all the necessary actions for persons to read and understand this document. Employees and managers are required to comply with the rules in this regulation. In case of violation of the specified values, people may face disciplinary measures. In case of serious violations such as risking the reputation of or financially damaging the company, relevant employees or managers will face measures such as termination or freezing of their employment contract. Kocaman Denizcilik reserves the right to impose sanctions regarding damages caused by persons who have committed a violation prior to or following the publication of this regulation. Every employee and manager must read this regulation and agree that the conditions specified are appropriate for him and that he will be held responsible in case of a violation of the same.

These Rules and Regulations come into effect from the moment they are published on the official website of the company and compliance with the rules shall be monitored and audited by the Company Disciplinary Board.