Code Of Ethics

AIM:

The purpose of this procedure is to implement within our company the ethical behavior standards that have been adopted, ensuring compliance with local laws and corporate regulations in the locations we work and promoting a working environment based on fundamental principles such as honesty, respect, fairness, and professionalism. This procedure aims to encourage employees to act in accordance with ethical values in the workplace, preserve the company’s reputation, and conduct themselves in a manner consistent with the company’s values.

SCOPE:

This procedure applies to all MP Technic employees.

RESPONSABILITIES:

This procedure is published by MP Technic management and is the responsibility of all employees to comply with ethical rules.

IMPLEMENTATION:

Basic Principles and Values:

The most fundamental principle in business ethics is honesty. In our company, we embrace and implement transparency, fairness, and responsibility as our core values.

MP Technic employees are expected to be honest, truthful, and to fulfill their promises. All employees must adhere to applicable laws, regulations, legal obligations, and company principles at every stage of their work. They should act with integrity, ethical values, and the principle of fairness in the workplace.

Employees are expected to consult with the Human Resources Department or their managers if they believe they are in a situation that may violate any laws or ethical rules related to their work.

Employees are obligated to comply not only with the local regulations in the country where they work but also with the corporate rules of our customers. If they are not familiar with these rules, they are expected to learn them from the relevant managers in their field of work.

Our company is particularly sensitive to the issue of illegal cigarettes and operates with a zero-tolerance policy. It is estimated that approximately 370 billion cigarettes are produced and traded illegally each year. It is known that this illicit trade deprives governments of approximately 40 billion dollars in taxes. This stolen revenue also funds other illegal activities. Illegal trade is taken very seriously by our company in this regard as well.

Employees are expected to immediately report any suspicious situation related to illegal cigarettes to their managers and our General Manager.

Confidentiality:

All employees must keep sensitive information such as customer data, trade secrets, or internal company information confidential. Unauthorized disclosure or misuse of such information is contrary to business ethics. The company’s and stakeholders’ confidential and proprietary information must be safeguarded and used appropriately.

All employees are obligated to protect all confidential information they acquire while working at MP Technic AŞ, even after they leave the company. They are not allowed to share it with third parties. For further details please check GN:PRS.04 Information Security Policy

Fair Competition:

Our company aims to protect the rights of customers and other businesses, and to promote healthy competition.

The company is committed to fair competition and strongly opposes practices that hinder competition, such as price fixing, bid manipulation, market sharing, and abuse of market dominance.

Employees are expected to respect the intellectual property rights of competitors and refrain from unauthorized use of competitors’ confidential information.

Workplace Discipline:

Employees are expected to exhibit respectful, organized, and professional behavior in the workplace. They should arrive at work on time, perform their duties properly, and show respect to their colleagues. All employees are required to adhere to workplace health and safety rules and are expected to alert non-compliant coworkers.

Our company has established various rules and instructions to ensure discipline and order in the workplace, define the rights and responsibilities of employees, and enforce work rules.

Our company has detailed the rules and regulations that employees working under an employment contract within the company, in jobs specified by the employer or employer representatives, must adhere to. The procedures and principles regarding the disciplinary actions and sanctions to be applied within the scope of job security for those who engage in behavior contrary to these rules or fail to act in accordance with the required integrity in their duties are outlined in İK.TLM.02 Discipline Instructions

Conflict of Interest:

Employees are expected to base their decisions related to work or their ways of doing business on the company’s interests, rather than their personal interests, at all times.

Employees should avoid conflicts of interest and should not engage in activities that jeopardize the interests of the company. If an employee’s personal interests conflict with the interests of the employer, the employee should disclose this conflict to the employer. This is in line with the principles of honesty and transparency.

Possible types of conflicts of interest that require disclosure and approval may include:

  • Personal relationships with other MP Technic employees
  • Personal relationships with suppliers
  • Personal relationships with customers
  • Financial relationships with suppliers
  • Having another job outside of MP Technic.

Upon reporting a conflict of interest to the Human Resources Department, the Human Resources Manager may consult with you and your manager to propose measures to mitigate the conflict of interest. In this case, employees are expected to implement the measures and, if there are any significant changes, to report them following the approval of the conflict of interest.

Corruption:

MP Technic has adopted a Zero Tolerance policy regarding corruption. Regardless of the type or method of corruption, embezzlement, facilitation payments, or bribery, there is no place for it in our business practices. Any form of corruption is contrary to company policies and may result in severe disciplinary actions and legal consequences. In this context,

  • Fighting corruption is our company’s top priority.
  • Business ethics, transparency, and honesty form the foundation of our business principles.
  • Ensuring full compliance with laws and regulations is our company’s responsibility.

All company executives, officers, employees, suppliers, agents, or other third parties acting on behalf of the company, wherever they may be located, or they are, are obligated to comply with local and relevant international legislation, as well as relevant company policies.

Providing or accepting gifts, meals, travel, or hospitality, particularly to a Public Official, directly or indirectly, with the intention of improperly influencing any party, especially for the purpose of gaining an unfair advantage, is strictly prohibited for company employees or for any third parties working on behalf of our company.

Gifts, hospitality, and entertainment must be given and received in a manner compliant with relevant laws and regulations. Additionally, they should not influence, nor create the perception of influencing, business decisions.

Respect and Inclusion:

Our globally operating company adheres to the Universal Declaration of Human Rights as a guide, and has adopted an approach respectful to human rights in the countries where it operates.

Our company is committed to treating all employees equally, offering equal pay for equal work, and equal rights and opportunities. Discrimination or disrespect based on a person’s race, gender, color, nationality, social status, ethnic background, religion, age, disability, sexual orientation, gender identity, family status, sensitive medical conditions, union memberships or activities, political views, or any other legally prohibited status is not tolerated.

Our company strictly prohibits all forms of discrimination, harassment, or bullying. This includes any adverse treatment based on race, gender, sexual orientation, religion, age, disability status, or other legally protected characteristics. All employees are expected to behave in a manner that promotes respectful, fair, and professional relationships in the workplace.

Our company commits to providing a work environment free from violence, discrimination, and harassment based on or arising from a person’s race, gender, color, nationality, social status, ethnic background, religion, age, disability, sexual orientation, gender identity, family status, sensitive medical conditions, union memberships or activities, political views, or any other legally prohibited status.

At MP Technic Inc., a zero-tolerance policy is adopted for physical, verbal, sexual, or psychological violence, bullying, or threats; and disciplinary actions such as verbal or written warnings, suspension, dismissal, or legal proceedings are implemented for employees who engage in such conduct.

Environmental Responsibility:

As a company, we are aware that sustainability is the most important element for our long-term values. At our company, environmental and social impacts are considered at every decision-making stage.

At MP Technic, we aim to improve our environmental performance by keeping up with global developments, scientific research, and technologies related to environmental management. We take into account climate-related risks and opportunities when determining our long and short-term strategies.

Our company commits to embracing environmental sustainability and continuously improving our environmental performance. We take and develop appropriate measures to minimize our environmental impact, use resources efficiently, and preserve natural habitats.

Our company promotes sustainable practices and responsible resource management to minimize its environmental impact.

All employees are expected to participate in regular training sessions aimed at fostering awareness of efficient resource use, spreading recycling consciousness, and focusing on social responsibilities.

Social Responsibility:

As a company, aware of our constant interaction with the environment we operate in, we aim to support the establishment of a sustainable relationship between the business world and society.

In this context, we support social responsibility projects and offer opportunities for our employees to volunteer in such projects. Employees can participate in social responsibility services outside of work hours or by using leave. Our company encourages voluntary participation and may grant up to an additional 3 days of leave per year to employees who can prove the time spent on these activities.

The areas of social responsibility supported within our company are defined as follows:

  • Sustainable living (Environmental protection, waste management, green energy, climate crisis, etc.)
  • Education
  • Equal opportunity
  • Gender equality

Reporting and Accountability:

Employees are required to immediately report any violations of the code of ethics and conduct, or any suspicious unethical behavior, to the Human Resources Manager. In case of encountering any suspicious situation, it must be reported through the following link. Reports made via this link are only communicated to the Human Resources Manager and the General Manager, and utmost importance is given to the confidentiality of both the reporting employee and the reported issue.

Conflict of Interest, Ethics Violation Reporting Link:

https://forms.office.com/Pages/ResponsePage.aspx?id=_9-Vxra5mUqzSNUC8owPQQq8-zuxSXpOtvEpuAe_QDpUREUyQlo1T0RFWlZWUDBDMUFBSkZUREFQRy4u

The Human Resources Manager, in conjunction with the General Manager, reviews the reports made and, if necessary, calls the disciplinary committee to action. The disciplinary committee is obligated to evaluate the situation transparently, based on principles of equality and fairness. Employees are given the opportunity to defend themselves if accused. The company management guarantees that reports will be kept confidential and assures that no retaliation will be taken against those who report in good faith.

For employees who violate company policies, our company implements the necessary disciplinary measures that have been previously established. Violations of the code of ethics and conduct can lead to disciplinary actions such as verbal or written warnings, suspension, dismissal, or legal proceedings.

All employees are required to fill out and submit the GN.PRS.03.EK.01 Employee Declaration of Ethical Conduct to the HR department once a year.

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