This CODE of BUSINESS CONDUCTS explains business practices that are applicable to all occasions our company may encounter. In this document, “Turcont”, “we”, “us” and “our” refer to TURCONT MUHENDISLIK IMALAT SAN ve TIC LTD STI. (short form: TURCONT Engineering & Manufacturing Ltd).
Since its founding, Turcont’s business practices have been governed by integrity, honesty, fair dealing and full compliance with all applicable laws. Turcont employees have upheld and lived this commitment in their every day responsibilities ever since, and Turcont’s reputation remains one of the Company’s most important assets today.
This Code of Business Conduct establishes certain non- negotiable minimum standards of behaviour in key areas.
The nature of this Code is not meant to cover all possible situations that may occur. It is designed to provide a frame of reference against which to measure any activities. Employees should seek guidance when they are in doubt about the proper course of action in a given situation, as it is the ultimate responsibility of each employee to “do the right thing”, a responsibility that cannot be delegated.
Employees should always be guided by the following basic principles:
- avoid any conduct that could damage or risk Turcont or its reputation;
- act legally and honestly;
- put the Company’s interests ahead of personal or other interests.
For the purposes of this Code, references to “employees” include employees, associates, officers and directors of TURCONT MUHENDISLIK IMALAT SAN ve TIC LTD STI. (short form: TURCONT Engineering & Manufacturing Ltd) (referred as Turcont hereafter) and its subsidiaries.
COMPLIANCE WITH LAWS, RULES AND REGULATIONS
Turcont and its employees are bound by the law. Compliance with all applicable laws and regulations must never be compromised. Additionally, employees shall adhere to internal rules and regulations as they apply in a given situation. Those internal rules are specific to the Company and may go beyond what is required by the law.
A Conflict of Interest occurs when personal interests of an employee or the interests of a third party compete with the interests of Turcont. In such a situation, it can be difficult for the employee to act fully in the best interests of Turcont.
Employees shall avoid Conflicts of Interest whenever possible.
If a Conflict of Interest situation has occurred or if an employee faces a situation that may involve or lead to a Conflict of Interest, the employee shall disclose it to his or her Line Manager to resolve the situation in a fair and transparent manner.
Our hiring and people development decisions will be fair and objective.
Immediate family members and partners of employees may be hired as employees or consultants only if the appointment is based on qualifications, performance, skills and experience and provided that there is no direct or indirect reporting relationship between the employee and his or her relative or partner.
These principles of fair employment will apply to all aspects of the employment, including compensation, promotions and transfers, as well as in case that the relationship develops after the respective employee has joined the Company.
Provided that they are equally suited as other candidates, priority may be given to children of Turcont employees with respect to internships, training periods, employment during holidays and similar short-term assignments.
OUTSIDE DIRECTORSHIPS AND OTHER OUTSIDE ACTIVITIES
We take pride in Turcont’s reputation and consider Turcont ’s best interests also in our outside engagements and activities.
Outside of Turcont, no activities shall be pursued if such activities will interfere with the employee’s responsibilities for Turcont, or if they create risks for Turcont’s reputation or if they in any other way conflict with the interests of Turcont.
When in doubt about the permissibility of an activity, employees shall consult with the Management of the company.
The following positions and activities are deemed acceptable only in case of prior authorization from a member of the Management:
- officer
- employee
- partner
- consultant
Authorization will be withheld if the position or activity is likely to conflict with Turcont’s interests or the employee’s responsibilities.
Unless requested by the Company to take up a particular position or activity, employees shall pursue outside activities and positions at their own risk and cost and within their spare time only.
Employees shall not compete with the Company. Nor shall they take personal advantage of business opportunities that they discover during the course of their employment, unless the Company expressly waives its interest in pursuing such opportunity.
If employees want to pursue business opportunities that might be of interest to the Company, they shall inform their Line Manager who will seek a management decision as to whether or not the Company wants to pursue the opportunity. Even if the Company decides against pursuing the opportunity, the employee may seize the opportunity on his or her own behalf only if it is clear that doing so will not result in direct or indirect competition with the Company’s operations.
Turcont is prepared to compete successfully in today’s business environment and will always do so in full compliance with all applicable antitrust, competition and fair dealing laws. Therefore, employees must at all times adhere to the following rules:
- Commercial policy and prices will be set independently and will never be agreed, formally or informally, with competitors or other non-related parties, whether directly or indirectly;
- Customers, territories or product markets will never be allocated between Turcont and its competitors but will always be the result of fair competition;
- Customers and suppliers will be dealt with fairly.
All employees, but especially those who are involved in marketing, sales and purchasing, or who are in regular contact with competitors, have a responsibility to ensure that they are familiar with applicable competition laws. When in doubt, the Management should be contacted in order to provide competition law advice and training.
We value and protect our confidential information and we respect the confidential information of others.
Confidential information consists of any information that is not or not yet public information. It includes trade secrets, business, marketing and service plans, consumer insights, engineering and manufacturing ideas, product recipes, designs, databases, records, salary information and any non-published financial or other data.
Turcont’s continued success depends on the use of its confidential information and its non- disclosure to third parties. Unless required by law or authorized by their management, employees shall not disclose confidential information or allow such disclosure. This obligation continues beyond the termination of employment. Furthermore, employees must use best efforts to avoid unintentional disclosure by applying special care when storing or transmitting confidential information.
Turcont respects that third parties have a similar interest in protecting their confidential information. In case that third parties, such as joint venture partners, suppliers or customers, share confidential information with Turcont, such information shall be treated with the same care as if it was Turcont’s confidential information. In that same spirit, employees shall protect confidential information that they have obtained in the course of their prior employment.
FRAUD, PROTECTION OF COMPANY ASSETS, ACCOUNTING
Employees must never engage in fraudulent or any other dishonest conduct involving the property or assets or the financial reporting and accounting of Turcont or any third party. This may not only entail disciplinary sanctions but also result in criminal charges. Turcont’s financial records are the basis for managing the Company’s business and fulfilling its obligations to various stakeholders. Therefore, any financial record must be accurate and in line with Turcont’s accounting standards.
Employees shall safeguard and make only proper and efficient use of Turcont’s property.
All employees shall seek to protect Turcont’s property from loss, damage, misuse, theft, fraud, embezzlement and destruction. These obligations cover both tangible and intangible assets, including trademarks, know-how, confidential or proprietary information and information systems.
To the extent permitted under applicable law, the Company reserves the right to monitor and inspect how its assets are used by employees, including inspection of all e-mails, data and files kept on Company network terminals.
Employees must never, directly or through intermediaries, offer or promise any personal or improper financial or other advantage in order to obtain or retain a business or other advantage from a third party, whether public or private. Nor must they accept any such advantage in return for any preferential treatment of a third party.
Moreover, employees must refrain from any activity or behaviour that could give rise to the appearance or suspicion of such conduct or the attempt thereof.
Employees should be aware that the offering or giving of improper benefits in order to influence the decision of the recipient, even if he or she is not a government official, may not only entail disciplinary sanctions but also result in criminal charges. Improper benefits may consist of anything of value for the recipient, including employment or consultancy contracts for closely related parties.
Employees must be aware that election laws in many jurisdictions generally prohibit political contributions by corporations to political parties or candidates. Turcont has adopted a policy not to make such contributions except for the parent company in its country of origin. Any such contributions and any deviations from such policy must be approved by the Management.
Employees shall not be influenced by receiving favours nor shall they try to improperly influence others by providing favours. Employees may only offer or accept reasonable meals and symbolic gifts which are appropriate under the circumstances, and they shall not accept or offer gifts, meals, or entertainment if such behaviour could create the impression of improperly influencing the respective business relationship.
When assessing the situation in light of the above, employees shall consult the policy applicable in their Market. If no such policy is available, they shall apply the most restrictive local practice in order to avoid even the appearance of improper dealings. When in doubt, the employee shall seek guidance from his or her Line Manager or the Management.
No employee shall offer to or accept from any third party gifts taking the form of any of the following, whatever the value involved:
- money
- loans
- kickbacks
- similar monetary advantages
Turcont respects the personal dignity, privacy and personal rights of every employee and is committed to maintaining a workplace free from discrimination and harassment. Therefore, employees must not discriminate on the basis of origin, nationality, religion, race, gender, age or sexual orientation, or engage in any kind of verbal or physical harassment based on any of the above or any other reason.
Employees who feel that their workplace does not comply with the above principles are encouraged to raise their concerns with the Management.
It is each employee’s responsibility to ensure full compliance with all provisions of this Code and to seek guidance where necessary from their Line Manager, or from the Management.
To “do the right thing” and to ensure the highest standards of integrity is each employee’s personal responsibility that cannot be delegated. When in doubt, employees should always be guided by the basic principles stated in the introduction to this Code.
Any failure to comply with this Code may result in disciplinary action, including the possibility of dismissal and, if warranted, legal proceedings or criminal sanctions.
REPORTING ILLEGAL OR NON-COMPLIANT CONDUCT
Employees shall report any practices or actions believed to be inappropriate under this Code or even illegal to their Line Managers or the Management.
All complaints shall be properly investigated. Turcont prohibits retaliation against any employee for such reports made in good faith, while it also protects the rights of the incriminated person.
GUIDANCE ON TURCONT’S COMMITMENT AGAINST BRIBERY AND CORRUPTION
“Turcont condemns all forms of bribery and corruption. It promotes its products on the basis of their value, quality, price, competitiveness and sustainability, and not on the basis of improper advantages.”
This document provides additional and complementary guidance on the two sections of the Code of Business Conduct which form the cornerstone of Turcont’s commitment against bribery and corruption: “Bribery and corruption” and “Gifts, meals, entertainment”. It applies in every market, even if local law is more lenient.
More stringent local laws or procedures always take precedence and local market and/or business rules may be introduced in order to detail specific local limits and procedures.
Turcont is committed to a strong work ethic and strictly prohibits its employees, service providers and agents from engaging in bribery and corruption, as well as any conduct which could give rise to the appearance or suspicion of such illicit activities. Bribery is defined as an offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or a breach of trust in the conduct of the enterprise’s business.
Gifts offered to third parties (such as customers, distributors, vendors, service providers, government officials, or other professionals) must be reasonable, modest and appropriate under the circumstances and must not create the appearance of improper influence or illegitimate advantage. Gifts should normally be offered only on customary business and cultural occasions and shall never include cash or cash equivalents.
In addition to satisfying the above-noted general criteria, gifts to government officials of non-Turcont products must also be approved in advance by the Management. No gifts of any nature should be offered in the context of a decision affecting Turcont by the relevant authority or government official which is pending or imminent.
MEALS, HOSPITALITY AND ENTERTAINMENT
Turcont may offer reasonable and appropriate meals and hotel accommodation to third parties who attend business meetings, conferences or events which are hosted, supported or sponsored by Turcont provided they are conducive and proportionate to the legitimate underlying purpose.
Reasonable and appropriate entertainment, local tours, cultural and sporting events and the like may be offered to third parties only in conjunction with legitimate business meetings, conferences or events hosted, supported or sponsored by Turcont. They may never be provided on a stand-alone basis.
Turcont employees must never pay or use third parties to pay an unofficial gratuity to government officials or employees in order to secure or expedite routine administrative actions, such as customs clearances, visas, permits or licenses.
SCHOLARSHIPS, GRANTS, CHARITABLE CONTRIBUTIONS AND NON-COMMERCIAL SPONSORSHIPS
Turcont may offer scholarships, grants, charitable contributions or non-commercial sponsorships to support the advancement of knowledge in science, nutrition, healthcare, or to support other socially beneficial purposes. They must never be made to procure an improper advantage to Turcont nor be made conditional upon an individual’s or organization’s agreement to recommend or promote Turcont products.
When a market or business provides this kind of economic support, it shall apply appropriate review and approval procedures, including an evaluation of the proposed recipient’s reputation, track record, the suitability for the intended purpose, and the socially responsible benefits in terms of nutrition, science, medicine and public welfare.
Corporate Affairs must be involved in the review and selection process. All material scholarships, grants, charitable contributions and non-commercial sponsorships must be approved by the Management and documented in writing.
Turcont has adopted a general policy prohibiting Turcont’s affiliates from making political contributions to political parties or candidates. Any deviations from this general policy must be approved by the Management, in accordance with applicable laws and pursuant to principles of good corporate governance.
This general policy does not preclude Turcont’s affiliates from organizing and administering political action committees which are funded by Turcont employees in full compliance with applicable law.
THIRD PARTY COMPLIANCE AND TURCONT DUE DILIGENCE
Turcont takes care in its dealings with third parties and will never use them to pay bribes or engage in corrupt practices. Turcont requires its suppliers, service providers, distributors and third parties acting on its behalf to act with integrity and to comply with anti-bribery laws.
The decision to purchase from a certain supplier, to engage a service provider, or to appoint a commercial agent or distributor, must follow an appropriate due diligence process which is consistent with Corporate Guidelines. If it becomes clear or appears likely during the course of the relationship that a third party is engaging in inappropriate or illicit practices, then the Management must be immediately consulted for guidance.
As part of its internal controls against corruption, Turcont requires that all business transactions and financial flows be properly recorded, classified and documented, including those concerning the company’s provision of gifts, hospitality, travel, entertainment, scholarships, grants and charitable contributions.
COMPANY REGISTRATION & CONTACT
Official company name : TURCONT MUHENDISLIK IMALAT SAN ve TIC LTD STI.
(unofficial short form: TURCONT Engineering & Manufacturing Ltd)
Registered in : Turkey
VAT Office: Selcuk VAT no: 5760512145 Chamber no: 58821
Address : Fevzi Cakmak Mahalesi, Elit Sanayi Sitesi, 10757. Sokak, No: 6A, ZIP Code: 42050, Karatay - KONYA, TURKEY
Telephone : +90 332 606 09 48
Fax : +90 332 606 09 49
Email : info@turcont.com
