Ethical Principles

1. Ethical Principles

Business ethics principles; It is valid for managers, employees, business partners, consultants, representatives and employees of these stakeholders, including members of the Board of Directors of Traçim Çimento.

Our Ethical Principles; It contains the principles that all employees and stakeholders of Traçim Çimento must follow and avoid while fulfilling their duties and responsibilities. At the same time, business ethics rules were created on the grounds that all necessary legal regulations and requirements will not respond to all situations.

2. Rules of Business Ethics That Employees Must Follow

Compliance with business ethics principles is the primary responsibility of all employees. In this regard, all our employees;

- To question whether the activities and decisions taken in all processes involved, firstly, comply with the laws and regulations, and then whether they comply with the business ethics principles determined by Traçim Çimento,

- To detect possible or possible violations by the employee or other employees, and in case of witnessing, to report this situation to the manager, the relevant unit and the Ethics Committee through reporting channels,

- To act in cooperation with the persons and committees conducting the investigation in possible investigation processes due to behaviors contrary to the principles of business ethics, to keep confidential the information obtained regarding the process in case of involvement in the investigation process, to provide all kinds of information, documents and evidence that may help the conduct of the investigation to the relevant person and /or sharing with the Ethics Committee,

- To prioritize the interests of Traçim Çimento in decision-making processes related to his/her duty, not to seek personal benefit and to avoid any actions and transactions that will harm Traçim Çimento, to protect the brand image of the company, to keep its trade secrets, to avoid behaviors that may create unfair competition,

- To protect all tools and assets belonging to Traçim Çimento and/or assigned to it and to use them for their intended purpose.

are obliged to comply with the rules.

2.1. Political Activities

All employees can participate in political party, union, association activities etc. individually and voluntarily, provided that it is legal. Although students have the right to participate in activities, times outside working hours and special resources should be used for these activities. In these studies, behaviors such as company name and reputation, use of company resources, and propaganda, promotions, conversations, presentations, etc. regarding political views are used. Carrying out activities within the company is within the scope of ethical violation.

Managers cannot ask our employees to do political work or become a member of a party or union. Employees should take care not to become a member of any club, association or cooperative by using the company name and position.

- In social media communication, it should be clearly stated that the posts do not represent Traçim Çimento in any way.

- Content that disparages another company employee, customers, suppliers, competitors and all other stakeholders should be avoided in posts.

- In social media posts, private, confidential documents and information about Traçim Çimento, any institution or organization with which it has a business relationship, or any of its customers, trade secrets, legal processes, internal official investigations, information not disclosed to the public, and information regarding lawsuits. should not be published or shared.

- It is expected that the content of the posts should not be considered racism, discrimination, harassment or insult, and that they should not support acts of violence and/or crime.

- Comments and shares made by third parties about Traçim Çimento or questions asked about any subject about the company should not be answered. When such a situation is encountered, the relevant business unit within the company should be informed.

- Care should be taken to ensure that there is no content that violates personal data protection legislation in the posts.

- Traçim Çimento employees are individually responsible within the legal framework for all their posts on social media channels. Possible sanctions are not the company's; It is the individual's own responsibility.

2.5. Corporate Opportunities

Employees are responsible for keeping confidential the information provided to them by the company as part of their duties or which they may learn due to being at the workplace and which provides the company with a competitive advantage, not to use the information in any way after leaving the job, not to engage in activities that will create an unfair competitive environment, and not to disclose it to third parties without the written permission of the company. .

If employees want to evaluate a business opportunity that the company may be interested in, they will notify this situation to the managers, and the managers will submit the issue to the management decision as to whether they are interested in the job opportunity. Even if the company decides not to be interested in the job opportunity in question, the employee is required to use this opportunity on his own behalf, provided that doing so does not constitute direct or indirect competition with the company's activities.

2.6. Protection of Company Assets and Resources, Accounting Records, Storage and Protection of Documents

Company assets and resources should not be used for the benefit of any person or purpose other than personal interests or company activities.

Behaviors such as theft of company assets or any assets belonging to employees, taking company products, equipment or information out of the company, embezzlement, intentional misreporting of time spent or expenses incurred are crimes according to both business ethics principles and criminal laws. is evaluated.

Since time is one of the most important resources, dealing with personal matters during working hours is also against the principles of business ethics. Employees cannot work in another job, paid or unpaid, during working hours and during annual leave, cannot work anywhere to generate income, or take part in management or consultancy positions in other companies. During working hours, our employees are required to complete their private meetings within a reasonable period of time, in connection with the subject of the visit and in a way that does not hinder the workflow.

Accounting books, records and accounts of the company; It must always fully and accurately reflect the company's financial transactions. This includes timesheets, vouchers, receipts, invoices, expense statements, payroll and other employee benefit records, performance evaluations, and other important company information.

Knowingly misrepresenting or improperly recording business and financial records or falsifying the company's business records constitutes a violation of ethical rules. It is the duty of all employees, not just accounting and finance department employees, to ensure that records are kept completely and accurately.

2.7. Company Computers and Internet

Since connecting to the Internet means putting the computer used and the company's computer network at certain risk, such activities must be carried out in accordance with the methods and rules approved by the company.

E-mail addresses other than those allocated by the company should not be used in exchanging information regarding company activities.

Since all documents, including e-mails and correspondence, belong to the company, the company has the right to review these materials.

It is not appropriate to use company computer resources and communication systems in the following manner:

- Messages that are likely to cause loss or damage to the recipient's business or systems, humiliating or degrading messages,

- Usage patterns that interrupt the work of the employee or others,

- Forms of use that aim to encourage the employee to take an unethical action,

- Harassing others, making discriminatory posts,

- Making and sending inappropriate posts of sexual and political content

- Online gambling and gaming,

- Downloading software to the company information system without the permission of the relevant unit,

- Infringing the copyright, trade secret, patent or intellectual property rights of others.

2.8. Confidential Information / Confidentiality of Personal Information

Traçim Çimento, Personal Data Protection Law In line with their awareness of their responsibilities within the scope of the Company, it expects all managers and employees to fully implement the procedures regarding the protection of information that can be considered confidential and personal. The behaviors that employees must comply with within the scope of confidentiality and protection of personal information are as follows:

- Any information classified as confidential information / personal information should not be shared with third parties and/or institutions unless requested by official authorities or relevant laws and regulations.

- Any information classified as confidential / personal information should not be modified, copied or destroyed.

- Personal data of employees are recorded only as required by law and within the scope of the activity cycle.

- Passwords and authorizing information assigned to individuals to access information are kept confidential and should not be shared with other people.

- Confidential and personal information should not be discussed in any open environment where third parties may learn this information.

- Before sharing information that must be shared within the scope of legal legislation and/or business relations, a confidentiality agreement regarding information security and confidentiality must be signed.

- Employee wages, benefits, etc. No personal data, such as personal information, should be shared with third parties.

- Even if the business relationship of managers and employees with Traçim Çimento ends, their responsibilities regarding the storage and confidentiality of this information continue in accordance with the law, and legal proceedings will be initiated against former employees who disclose this information even if their duties end.

2.9. Patents, Trademarks and Copyrights

Protection of intellectual property elements, including patents, trade secrets, copyrights, names and trademarks, scientific and technical information, and know how, is of great importance for the company to maintain its competitiveness. Therefore, any unauthorized distribution, reproduction, use, sale, in any form, for any purpose, for any use of the intellectual property is prohibited. It is the collective responsibility and duty of employees to establish, protect and defend the company's intellectual property rights on everything that is commercially important.

While trying to protect the company's intellectual property rights, the legal intellectual property rights of other individuals and organizations must also be respected. Using the intellectual property rights of other people or institutions without permission may result in legal sanctions.

2.10. Conflicts of Interest

A conflict of interest occurs when the personal/family/financial interests of an employee or a third party conflict with the interests of the company.

By taking advantage of the existing positions and powers of the employees; Personal interest and gain should not be derived from decisions regarding individuals and organizations with whom business relations are established personally, through family or relatives.

While the employee continues his/her duty in the institution, he/she should not personally work, consult, or provide services for any supplier, contractor, competitor, or customer in whose selection he/she took part.

Likewise, employees cannot establish debt-creditor, tenant-lessor or surety relationships with other employees or managers in the workplace, and they should not be in such relationship of interest.

Company resources, brand and power should not be used for personal benefit, and situations that will negatively affect the corporate reputation should be avoided.

All exceptional cases are subject to the approval of the company's Board of Directors.

If a conflict of interest has arisen or an employee has encountered a situation that has the potential to create a conflict of interest, the employee must share this situation with his manager, Human Resources or the Ethics Committee.

Conflict of interest does not always mean violation of business ethics principles. It may be possible to reach a solution if the issue is shared with the senior manager, human resources or the Ethics Committee at the right time. Failure to report such an issue is considered a violation of business ethics principles.

2.11. Personal Investments and Transactions

Traçim Çimento respects the right of employees to direct their investments as they wish. However, employees should also avoid situations that may lead to a possible conflict or perception of such a conflict between their own interests and the company's interests.

Investments that may affect or appear to affect the ability to make decisions on behalf of the company should be avoided.

2.12. Outside Business and Other Non-Partnership Activities

Employees must avoid activities that would conflict with their duties within the company and the interests of the company and damage the reputation of the company. If it is not an activity requested by the company, employees should do their outside activities outside of work, at their own risk and with their own means.

There is no harm in the employee engaging in activities that serve the social good, as long as they do not disrupt their duties in the company.

With the knowledge of the company management or the Ethics Committee, seminars and conferences can be attended as speakers and sectoral visits can be made to develop the company's brand.

2.13. HGifts, Invitations, Hospitality and Other Treats

It is essential that Traçim Çimento employees do not accept gifts of high economic value that are clearly in return for a reward or that may affect their impartiality, decisions and behavior during their duties, and do not attempt to provide gifts, hospitality or benefits to third parties/institutions that may have such effects.

Employees should not be influenced by obtaining privileges and should not try to influence others by granting them privileges.

Any gift, entertainment or entertainment that may create the perception that it could have a significant impact on a commercial transaction in which the company has started or may start operating, or could otherwise lead to a conflict of interest, is not tolerated.

It is essential not to give or offer gifts, directly or indirectly, to persons/institutions acting on behalf of or in connection with the public institution, or to relatives of these persons, for the purpose of accelerating or rewarding a decision of the public institution.

Likewise, in an official legal case, it is prohibited to act in favor or against a party or to cause this perception and to provide indirect or direct benefit to Traçim Çimento in this way.

Giving or receiving gifts, invitations or hosting are traditional behaviors in most geographies to increase goodwill among business partners. Requests in this context must be reported to the senior manager, human resources unit or Ethics Committee. In cases where the gift giver does not return the gift or if the return of the gift may disrupt the commercial relationship, these gifts; It is forwarded to the human resources unit to be used in donations and rewards.

Gifts; Expenses for gifts, meals and entertainment activities given for meals and entertainment must be reasonable and must be recorded completely and accurately in the company records.

When business gifts are sent to customers or suppliers or invitations to participate in events are made, it is essential that the expenses are not made from the personal budgets of the employees, and such expenses must be covered from the company budget with management approval.

No employee should offer any of the following to a third party or accept a similar offer from a third party, regardless of value:

- Cash Money

- Debt

- Commission

- Similar material advantages (cheque, property, housing, position, special discount, commission, discount, deduction and facilitating payment, any movable or immovable bond, real estate or real estate, gift voucher, gold)

In organizations such as seminars and conferences attended on behalf of the company, gifts with symbolic value such as plaques may be accepted as a sign of goodwill of the business relationship.

Invitations to meals and events that comply with local standards for business dinners and events attended by customers, business partners, suppliers, or giveaways of reasonable value within the framework of relationships may be accepted.

2.14. Relatives and Friends

Many employees have relatives and friends who are employed by or invest in the company's customers or suppliers. Provided that the restrictions arising from the legal legislation to which the company is subject are taken into account;

- You do not have discretion in dealing with any of these companies as part of your role within the company; or

- As long as the relative/friend does not do business with the company on behalf of the other company, it does not cause any conflict of interest.

If there are restrictions in the laws to which the company is subject, these restrictions are applied first.

There may be people you know who work or have shares in companies that are customers or suppliers of the company. If doing business with such a customer or supplier, care should be taken to ensure that the relationship does not affect, or appear to affect, behavior in the best interest of the company.

In cases where it is uncertain whether the situation will cause a problem or not, the manager, Human Resources unit or Ethics Committee should be consulted.

If a family member works in a government institution that has the potential to influence the activities of a customer, potential customer, supplier or company with which the institution cooperates, this situation must be reported in writing to a senior manager, human resources unit or the Ethics Committee.

Employees; He/she should not be involved in the process of superior-subordinate relationships, performance, wages, rewards, supervision and promotion decisions with relatives and friends.

2.15. Insider Trading

For the purpose of obtaining any commercial benefit; Securities such as stocks, bonds and options should not be bought or sold by using inside information (financial results and statements, changes in dividends, possible company mergers - divisions or joint ventures, developments in important cases and significant changes in management), non-public information should not be used or should not be shared with third parties.

3. Competition and Market Rules

Traçim Çimento has adopted a zero tolerance policy regarding corruption and bribery in its activities together with all its stakeholders.

Examples of bribery include making a payment to a public official or private company official to encourage the establishment or continuation of a business relationship, to influence the outcome of an administrative audit or inspection, or to influence tax or other legal obligations.

Anything of value; It means anything material or intangible that may be of value to a public official or private company official, including cash, gifts, meals, entertainment, job opportunities, employment offers. Although there is no financial limitation, anything of value is considered a bribe, regardless of its amount.

Employees should be aware that providing or offering to provide benefits to the other party in order to influence the other party's decision may result in not only disciplinary sanctions but also criminal sanctions, even if that person is not a public official.

In this regard, Traçim Çimento employees are expected to act in accordance with the following rules of conduct:

- In all processes carried out by Traçim Çimento, advantageous situations should not be created in exchange for privileges in relations with third parties and institutions, and offers to this effect should not be accepted.

- In case of any request or offer that may be considered as corruption or bribery, the relevant person and/or units should be informed immediately.

- Personal loans, privileges or discounts should not be requested from customers, suppliers and other third parties and/or business partners.

Even if there is no behavior that can be considered as bribery or corruption, if such a situation is witnessed or suspected, the relevant person and/or units must be informed immediately. Failure to inform relevant persons and/or units despite knowing or witnessing the behavior in question is considered indirect participation in the behavior in question.

3.1. Integrity in Marketing

Traçim Çimento is ready to compete successfully in today's business conditions and will continue to do so in compliance with all applicable anti-trust, competition and fair dealing laws, rules and regulations. For this reason, employees must always act in accordance with laws, rules and regulations. Unlawful behavior of the employee is unacceptable, even if it is in line with the interests of Traçim Çimento.

3.2. Business Intelligence

Collecting or benefiting from publicly available information about other institutions while conducting our activities is generally not against the law or the rules of business ethics. Employees may collect, share and use publicly available information about our competitors. However, in order to obtain such information, in no case should unethical and illegal methods such as false statements, deception, theft, espionage or bribery be used or third parties should be requested to resort to such methods.

3.3. International Trade Restrictions

3.4. Prevention of Money Laundering Activities

In order to prevent money laundering activities, as an employee, the company's reputation must be protected and the principle of honesty must be prioritized by assisting the authorities in revealing possible money laundering activities. Employees; Must exercise diligence in supplier selection and management to verify the identity and financial existence and history of customers, business partners and all other third parties, and to confirm that payments are made from appropriate sources.

In a suspicious case, such as a customer who avoids sharing clear information about himself or wants to make payments in advance, and if it is thought that there are some indicators that indicate dirty money, the situation should be immediately reported to the relevant manager, human resources unit or Ethics Committee.

4. Our Responsibilities Regarding Stakeholders

4.1 Our Responsibility Towards Employees

4.2 Our Responsibilities Toward Customers

The common goal and responsibility of Traçim Çimento employees is to ensure unconditional customer satisfaction and loyalty. It is approached from a perspective that responds to customers' needs and demands as quickly and accurately as possible. Even when company interests are at stake, incomplete or incorrect information should not be given to customers in promotional activities, and commitments should be fulfilled under agreed conditions.

There is no discrimination between customers based on race, color, religion, gender, sexual orientation, gender identity or expression, national origin, age, disability, etc., and all customers are served under the same conditions and standards.

Information regarding customers must be collected and stored as required by law and, when necessary, destroyed when necessary, in accordance with existing laws. Customer information should not be used for purposes other than its intended purpose and should not be shared with third parties.

4.3 Our Responsibility Towards Competitors

In relations with competitors, we comply with national and international laws. Except for the provisions specified by law, the company Employees are expected to behave in accordance with the following rules of conduct:

- While collecting information about competitors, one should not engage in illegal or irregular activities (theft, entering private property, secret recording, wiretapping, bribery, untrue statements, etc.).

- Untrue statements should not be made about competitors for any purpose.

- There should be no illegal agreements with competitors that aim or have the effect of restricting competition in an unlawful manner, such as jointly fixing or fixing prices, sharing markets and submitting bids for tenders.

- The company's pricing and distribution policies, supplier selection or prices, customer selection, credit and maturity policies, advertising policies or other similar information regarding competition should not be shared with competitors.

4.4. Our Responsibility Toward Suppliers/Business Partners

When determining our suppliers and business partners (consultants, service providers, representatives); Whether they carry out their activities in accordance with laws and regulations, whether they respect the rights of their employees, their compliance with human rights, sustainability principles and Traçim Çimento business ethics principles are taken into consideration.

Personal interest/business relationships should not be entered into with individuals/organizations with which the institution has commercial relations, in order to gain unfair advantage.

4.5. Our Responsibility Towards the Environment

Fulfilling its legal and social responsibilities, Traçim Cement acts with its advanced technology and high environmental awareness during its operations. This approach It takes care to fulfill its responsibilities in matters such as protecting the environment and natural resources and contributing to the social and economic development of the society.

The company expects all employees and collaborating stakeholders to act in accordance with all relevant legal requirements in order to reduce and eliminate the negative impacts it may have on the environment and society.

4.6. Our Social Responsibility

The company is sensitive to the needs of the society, as an integral part and participating member of the country and the society in which it lives. It contributes to the improvement of living standards with all its employees within its means.

Within the scope of serving social benefit, the protection of human rights, social responsibility projects, and the elimination of crime and corruption have been determined as top priorities.

At Traçim Çimento, the employment rules and age limits determined by law are respected. A policy of zero tolerance has been adopted for all forced labor practices, including debt-paying labor, military labor and all forms of human trafficking.

4.7. Our Responsibility Towards the State

If it is unclear which laws apply, or if there is a belief that there is a conflict between different applicable laws, the legal department should be consulted before proceeding.

Implementation of the Ethical Principles is the responsibility of the Ethics Committee. Ethical Principles; It is implemented by full-time and part-time employees, including senior managers.

5. APPLICATION OF ETHICAL PRINCIPLES

Ethics Committee;

- Ensuring that the principles of business ethics are implemented without exception in all relations of Traçim Çimento with its internal and external stakeholders, and ensuring that events and/or behaviors alleged to be contrary to the principles of business ethics are evaluated and investigated in accordance with the procedures.

- If situations contrary to the principles of business ethics are detected, it is responsible for deciding on the sanctions to be applied for such situations and resolving them.

is responsible.

The Ethics Committee reports the investigation processes carried out and concluded to the Board of Directors.