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.
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.
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.
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 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.
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
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.
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.
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.
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.
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.