Rules of Ethical Behavior that Employees Must Follow

2.1. Information Security

All company regulations, commitments, and directives regarding information security are accepted as complementary to the following articles.

2.1.1  Intellectual Property Rights

2.1.2  Information Management

2.1.3  Security and Crisis Management

2.1.4  Confidentiality

2.1.5  Social Media Use

2.2. Avoiding Conflicts of Interest

2.2.1  Not working for the benefit of oneself or one’s relatives

2.2.2 Representation and participation in event invitations

Participation in athletic activities, domestic/international travel, and similar invitations that are influential or may be perceived as such in making decisions, apart from conferences, receptions, promotional events, seminars, etc. that persons or institutions who are or have the potential to be in a business relationship host and that are open to general participation, are subject to the approval of the General Manager.

2.2.3 Those Who Have Quit Working with the Community

2.2.4 Sharing and Trading Internal Information (Insider Trading)

2.3. Combatting Corruption

Tosyalı Holding and the group companies face bribery and all kinds of corruption. Corruption harms commercial life, institutions, and their employees and irreparably damages commercial reputations and dignity. Tosyalı Holding and its group companies are incredibly meticulous and sensitive on the topics of combatting bribery and corruption. All employees and third parties operating on behalf of the company are obligated to comply with the rules for combatting corruption and with the relevant legislation.

2.3.1 Receiving and Giving Gifts

Tosyalı Holding and its group companies prohibit as a principle all employees from entering relationships with all third parties, including customers, suppliers, vendors, authorized sellers, and authorized services, that might create the impression of providing material interests, including the proposal and acceptance of gifts, invitations, and hospitality.

The criteria specified below must be complied with in executing relationships with private or official persons or institutions wanting to establish or maintain a relationship with Tosyalı Holding and its group companies:

2.3.2 Combatting Bribery and Corruption