ENSARI DERI GIDA SANAYI VE TICARET A.S.

PRINCIPLES OF ETHICAL CONDUCT


Ensari Deri Gida Sanayi ve Ticaret A.S. aims to be the ideal institution employing the most successful and competent professionals who added value that will provide continuous growth and development, and which everyone is proud to take part. Ensari Deri Gida Sanayi ve Ticaret A.S. values its employees and respects employee rights. “Happy Employee=Happy customer!! policy is one of the basic principles adopted by Ensari Deri Gida Sanayi ve Ticaret A.S.

OUR FUNDAMENTAL PRINCIPLES REGARDING RELATIONS WITH EMPLOYEES

• Recruiting qualified young people and experienced professionals who will carry our company forward is one of our goals in this regard.
• Ensari Deri Gida Sanayi ve Ticaret A.S. rewards success with its effective and objective performance evaluation systems and practices within the framework of fair and competitive wage policies.
• Ensari Deri Gida Sanayi ve Ticaret A.S. adheres to the principle of grounding its employment-related decisions on qualifications, merit, performance and other work-related factors.
• Ensari Deri Gida Sanayi ve Ticaret A.S. does not tolerate unlawful discrimination in employment.
• Ensari Deri Gida Sanayi ve Ticaret A.S. aims to increase the loyalty of its employees to the company by providing equal opportunities in promotion, training, development and rewarding.
• In Ensari Deri Gida Sanayi ve Ticaret A.S., maintenance of work peace is essential.
• Ensari Deri Gida Sanayi ve Ticaret A.S. and perpetuates a work environment that is transparent and encourages mutual respect.
• Ensari Deri Gida Sanayi ve Ticaret A.S. under no circumstances allow acts, practices and behaviors that are humiliating, intimidating and hostile. It absolutely does not allow harassment in the workplaces.
• Ensari Deri Gida Sanayi ve Ticaret A.S. attaches importance to the opinions and suggestions of its employees. All kinds of feedback, suggestions and opinions from the employees are evaluated and responded, and afterwards motivation-enhancing measures are taken.
• Ensari Deri Gida Sanayi ve Ticaret A.S. keeps private information about its employees and does not disclose to third parties without the employee's permission, unless there is a legal obligation.


OUR FUNDAMENTAL PRINCIPLES REGARDING RELATIONS WITH SUPPLIERS

• Mutual value is d in relations with suppliers,
• Communication with suppliers is carried out clearly, directly, in accordance with laws and procedures,
• Supplier ion is decided by objective criteria,
• Reasonable confidentiality and occupational safety rules requested by the supplier are followed during supplier inspections and visits.


OUR FUNDAMENTAL PRINCIPLES REGARDING RELATIONS WITH SHAREHOLDERS

• Ensari Deri Gida Sanayi ve Ticaret A.S. protects the statutory rights and interests of its shareholders.
• It makes the necessary effort to value in return for the resources provided by its shareholders, distributes the resulting profit to the shareholders or directs them to investment,
• All necessary studies are performed to represent the "ENSARI" brand in the best way in the society and to increase its prestige.
• Ensari Deri Gida Sanayi ve Ticaret A.S. by keeping in constant communication with its stakeholders, benefits from their criticism and suggestions and ensures the maintenance of positive relations,
• It ensures that the matters that need to be disclosed about the companies are announced fully, timely and accurately to its shareholders and the public,
• Ensari Deri Gida Sanayi ve Ticaret A.S. is managed within the framework of the ongoing trust and honesty principles since its establishment, our company's resources, assets and working time are managed with an awareness of efficiency, targeting sustainable growth and profitability.
• Ensari Deri Gida Sanayi ve Ticaret A.S. In order for its shareholders to have equal and simultaneous information, it makes Non-disclosure Agreements with its employees who have access to "in-company information".


OUR FUNDAMENTAL PRINCIPLES REGARDING RELATIONS WITH THE STATE

• Ensari Deri Gida Sanayi ve Ticaret A.S. is respectful and transparent to all institutions of the state.
• Ensari Deri Gida Sanayi ve Ticaret A.S. complies with the relevant laws, rules and regulations in all countries it operates and will operate.
• It manages, records and reports all business activities and accounting system fully and appropriately in accordance with the law.


OUR FUNDAMENTAL PRINCIPLES REGARDING THE RELATIONS WITH COMPETITORS AND IN TERMS OF COMPETITION

• Except for the limits permitted by the legislation, Ensari Deri Gida Sanayi ve Ticaret A.S. does not enter into agreements with competitors or other persons or organizations that directly or indirectly and behave accordingly which aim to prevent, distort or restrict competition, or that have or may cause such an effect.
• In cases it is in a dominant position in a particular market, alone or together with other undertakings, it does not abuse this dominant position.
• It does not negotiate and exchange information with competitors to determine the market and/or competitive conditions together.
• All kinds of meetings and transactions that may lead to the above-mentioned situations or that may be described as such, are avoided in meetings and negotiations during representing the Company such as associations, councils, chambers, professional associations, etc., and in other private or professional meetings and negotiations.


OUR BASIC PRINCIPLES REGARDING HSE-S AND SOCIAL PERFORMANCE

• Ensari Deri Gida Sanayi ve Ticaret A.S. constantly develops environmental policies and ensures their effective implementation.
• Ensari Deri Gida Sanayi ve Ticaret A.S. acts for the benefit of our country and the world, and shows an exemplary corporate citizenship with our employees, operators and suppliers.
• While maintaining its commitment to not harming people and protecting the environment, Ensari Deri Gida Sanayi ve Ticaret A.S. aims to develop services compatible with these purposes.
• Ensari Deri Gida Sanayi ve Ticaret A.S. aims to gain the trust of customers, shareholders and society in order to be a good neighbor and contribute to sustainable development.


OUR FUNDAMENTAL PRINCIPLES REGARDING SOCIAL RESPONSIBILITY

• Ensari Deri Gida Sanayi ve Ticaret A.S. supports activities that will contribute to economic and social development within the framework of a program.
• It shows sensitivity to the issues that concern the society and gives support for the positive development of the society.


OUR FUNDAMENTAL PRINCIPLES REGARDING ANTI-CORRUPTION

• Ensari Deri Gida Sanayi ve Ticaret A.S. does not tolerate activities such as bribery, insider trading, market abuse, fraud or money laundering.
• Facilitation payments also mean bribes and such payments are never allowed.


ETHICAL CONDUCT PRINCIPLES THAT EMPLOYEES SHOULD FOLLOW

The primary responsibility of all Ensari Deri Gida Sanayi ve Ticaret A.S. employees is to ensure that the ENSARI brand is mentioned with experience, honesty and trust, and to carry it forward. In this context, the expectations from Ensari Deri Gida Sanayi ve Ticaret A.S. employees are:

• To strictly comply with laws,
• To fulfill their duties within the framework of basic moral and human values,
• Not to gain unfair advantage from individuals and organizations for any reason, not to take or give bribes,
• To act in accordance with the relevant business ethics rules and all application principles that support these rules,
• Not to behave, make statement or correspondence that would undermine the company unless expressly authorized,
• Not to act in a way that will disturb and/or harm other employees, not to disturb the working environment,
• To take care of all material and moral assets of the company, including information and information systems, as if they were personal property, to protect them against possible loss, damage, misuse, abuse, theft and sabotage,
• Not to use working time and company resources directly or indirectly for personal and/or political activity and benefit,
• In order to secure the intellectual property rights of newly developed products, processes and software, to ensure that the legal processes are initiated and completed in a timely manner,
• To avoid -intentionally- unauthorized use of patents, rights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies,
• To ensure that all legal records are kept as required by law,
• To obtain the written approval of the senior management in order to respond to information requests from third parties that are classified as confidential for the company,
• To show the necessary meticulousness so that the statements and reports made by the company comply with the truth.
• To take necessary measures to protect company employees, information and information systems, business and administrative facilities against possible terrorism, natural disasters and malicious attempts,
• To ensure the continuity of the business with the least loss by making the necessary crisis planning related to the emergency crisis management to be d in situations such as terrorism, natural disaster, etc.,
• To take all kinds of measures to prevent the theft or damage of company assets,
• To act with the awareness that financial and trade secrets of Ensari Deri Gida Sanayi ve Ticaret A.S., information that will weaken the competitiveness of the company, personnel rights and information, agreements with business partners are within the framework of "confidentiality", and to ensure their protection and confidentiality,
• Not to disclose the information learned from work and the related documents with unauthorized persons and authorities inside and outside the institution for any reason, not to use them for speculative purposes (directly or indirectly),
• Not to use non-public information about the companies they work with, their customers, and other persons and companies with whom they do business for purposes other than the foreseen purpose, and not to share them with third parties without obtaining the necessary permissions,
• To avoid conflicts of interest. (Conflict of interest refers to all kinds of benefits affect or may affect the impartial performance of their duties by employees and provided to themselves, their relatives, friends or the persons or organizations with which they are in contact and the state of having any financial or personal interest in them.)
• Not to allow personal and private thoughts to affect the decisions taken within the body of Ensari Deri Gida Sanayi ve Ticaret A.S.
• Not to gain unfair advantage in favor of him/herself, his/her relatives or third parties by making use of title and authority,
• Paying attention not to fall into a conflict of interest with the current company in personal investments to be made,
• To take care not to prevent personal investments or activities other than any business activity in terms of giving time and attention to performing his duties at Ensari Deri Gida Sanayi ve Ticaret A.S. and to avoid such situations that prevent focus on core tasks,
• To inform the management and to obtain approval, in case the employee and the person in the primary decision-making position regarding the same job in the customer or supplier company are first-degree relatives,
• To inform the management in case it is learned that their relatives have shares or material interests in another company with which they have a commercial relationship.
• Participation in invitations such as conferences, receptions, promotional events, seminars, etc., which are open to general participation, or which are effective in decision-making or may be perceived as such, participation in invitations such as domestic / foreign trips, etc., organized by persons or institutions that are or have the potential to be in a business relationship, are subject to the approval of the General Manager.
• Sending gifts and accepting gifts (accommodation, meals, etc.) from customers, suppliers or operators with whom there is a business relationship or a potential to have the same, is limited to 100 Euros per year. All gift offers and acceptance of gifts over 100 Euros are subject to the written approval of the General Manager.


In the conduct of relations with private or official persons and organizations who want to establish or maintain a business relationship with Ensari Deri Gida Sanayi ve Ticaret A.S.;

• Except for the materials given in accordance with the commercial traditions, customs or souvenir / promotional materials, any gift that s the impression of the existence of an irregularity, that may cause a relationship of dependency or that may be perceived as such, cannot be accepted or offered.
• No discounts or benefits that may be perceived as inappropriate can be requested from suppliers, operators, tenants, customers, Group companies or third parties, cannot be offered to third parties, cannot be accepted when offered.


POLITICAL ACTIVITY BAN

Ensari Deri Gida Sanayi ve Ticaret A.S. does not make donations to political parties, politicians or political candidates without a decision of the board of directors. Demonstrations, propaganda and similar actions are not allowed within the boundaries of workplaces on these matters. Company resources (such as vehicles, computers, e-mails) cannot be used or made available for political purposes.

OUR BASIC PRINCIPLES REGARDING OCCUPATIONAL HEALTH AND SAFETY

Our company aims to fully ensure occupational health and safety at work and on the job. Employees act in accordance with the rules and instructions set for this purpose and take the necessary precautions.
Employees shall not keep any illegal goods or substances that may pose a danger to the workplace and/or workers.
No employee or operator can carry a gun, etc. in the workplace, even if it is licensed.
Employees shall not have drugs, addictive, mental or physical abilities limiting or abolishing substances, drink alcohol, shall not work in the workplace or within the scope of work, or drive while under the influence of such substances, except for those based on a valid doctor's report.

APPLICATION PRINCIPLES OF ETHICAL CONDUCT

Obligation to Notify Violations:

• If the employees learn or suspect that the Ensari Deri Gida Sanayi ve Ticaret A.S. Principles of Ethical Conduct or the laws and regulations to which the company is subject have been violated, they are obliged to convey this to their superior (first manager) and the General Manager and/or the Chairman of the Board of Directors to which they are affiliated.
• The disclosure of the person's statement to third parties, which will adversely affect the peace in the workplace or business relations, will definitely be prevented. It should be ensured that the notification mechanism is in the interest of the company.
• It is very important that the whistleblower is free from any intentions such as gossiping about the whistleblower or behaviors trying to negatively affect his career. In this respect, confidentiality, objectivity and compliance with ethical rules are extremely critical issues in the reporting and investigation process. It is obligatory for those who make the notification and who manage the process related to the issue to pay maximum attention to this issue.
• When deliberate false and/or slanderous statements are detected, it is interpreted as a violation of the code of ethics.


DISCIPLINARY APPLICATIONS

The following disciplinary penalties are applied after violations of the Principles of Ethical Conduct:

• If, as a result of the disciplinary committee's decision, there is an abuse that is determined to have been done knowingly, the necessary actions are taken in accordance with the relevant articles of the Labor Law and if necessary, employee is dismissed and legal action is initiated. Beneficial actions of the person knowingly gaining unfair advantage in the past cannot constitute a partial or complete excuse for the decision taken.
• If there is no abuse or if there is negligence arising from carelessness or ignorance, a verbal or written warning is given in accordance with the effect of the event.

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