{"id":5437,"date":"2026-04-11T15:51:56","date_gmt":"2026-04-11T12:51:56","guid":{"rendered":"https:\/\/www.metgun.com.tr\/?page_id=5437"},"modified":"2026-04-14T03:21:35","modified_gmt":"2026-04-14T00:21:35","slug":"ethics-compliance","status":"publish","type":"page","link":"https:\/\/www.metgun.com.tr\/en\/ethics-compliance\/","title":{"rendered":"Ethics &#038; Compliance"},"content":{"rendered":"\t\t<div data-elementor-type=\"wp-page\" data-elementor-id=\"5437\" class=\"elementor elementor-5437 elementor-5423\" data-elementor-post-type=\"page\">\n\t\t\t\t<div class=\"elementor-element elementor-element-8a61241 e-con-full e-flex e-con e-parent\" data-id=\"8a61241\" data-element_type=\"container\" data-e-type=\"container\" data-settings=\"{&quot;background_background&quot;:&quot;classic&quot;}\">\n\t\t\t\t<div class=\"elementor-element elementor-element-3bf2102 elementor-widget elementor-widget-heading\" data-id=\"3bf2102\" data-element_type=\"widget\" data-e-type=\"widget\" data-widget_type=\"heading.default\">\n\t\t\t\t\t<h3 class=\"elementor-heading-title elementor-size-default\">ETHICS &amp; COMPLIANCE<\/h3>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t<div class=\"elementor-element elementor-element-131d739 e-flex e-con-boxed e-con e-parent\" data-id=\"131d739\" data-element_type=\"container\" data-e-type=\"container\">\n\t\t\t\t\t<div class=\"e-con-inner\">\n\t\t<div class=\"elementor-element elementor-element-0c19bf2 e-con-full e-flex e-con e-child\" data-id=\"0c19bf2\" data-element_type=\"container\" data-e-type=\"container\">\n\t\t\t\t<div class=\"elementor-element elementor-element-2227f59 elementor-widget elementor-widget-text-editor\" data-id=\"2227f59\" data-element_type=\"widget\" data-e-type=\"widget\" data-widget_type=\"text-editor.default\">\n\t\t\t\t\t\t\t\t\t<div class=\"sidebar-menu-wrapper\">\n    <div class=\"menu-header-klon\">About Us<\/div>\n    <ul class=\"menu-list-klon\">\n        <li class=\"menu-item-klon\">\n            <a href=\"https:\/\/www.metgun.com.tr\/en\/about-us\/\">Metg\u00fcn Group<\/a>\n        <\/li>\n        <li class=\"menu-item-klon\">\n            <a href=\"https:\/\/www.metgun.com.tr\/en\/about-us\/#mission\">Our Mission<\/a>\n        <\/li>\n        <li class=\"menu-item-klon\">\n            <a href=\"https:\/\/www.metgun.com.tr\/en\/about-us\/#vision\">Our Vision<\/a>\n        <\/li>\n        <li class=\"menu-item-klon\">\n            <a href=\"https:\/\/www.metgun.com.tr\/en\/about-us\/#quality\">Quality Policy<\/a>\n        <\/li>\n        <li class=\"menu-item-klon active\">\n            <a href=\"https:\/\/www.metgun.com.tr\/en\/ethics-compliance\/\">Ethics and Compliance<\/a>\n            <ul class=\"sub-menu-list\">\n                <li class=\"sub-menu-item\">\n                    <a href=\"https:\/\/www.metgun.com.tr\/en\/ethics-hotline\/\">Ethics Hotline<\/a>\n                <\/li>\n            <\/ul>\n        <\/li>\n    <\/ul>\n<\/div>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t<div class=\"elementor-element elementor-element-f584b0f e-con-full e-flex e-con e-child\" data-id=\"f584b0f\" data-element_type=\"container\" data-e-type=\"container\">\n\t\t\t\t<div class=\"elementor-element elementor-element-3915330 elementor-cta--skin-classic elementor-animated-content elementor-widget elementor-widget-call-to-action\" data-id=\"3915330\" data-element_type=\"widget\" data-e-type=\"widget\" data-widget_type=\"call-to-action.default\">\n\t\t\t\t\t\t\t<div class=\"elementor-cta\">\n\t\t\t\t\t\t\t<div class=\"elementor-cta__content\">\n\t\t\t\t\n\t\t\t\t\t\t\t\t\t<h2 class=\"elementor-cta__title elementor-cta__content-item elementor-content-item\">\n\t\t\t\t\t\tEthics Hotline\t\t\t\t\t<\/h2>\n\t\t\t\t\n\t\t\t\t\t\t\t\t\t<div class=\"elementor-cta__description elementor-cta__content-item elementor-content-item\">\n\t\t\t\t\t\tWe consider compliance with policies and rules as our fundamental principle. You can report situations that you believe are not in line with Metg\u00fcn's Code of Business Conduct via phone, email, or through our web page.\t\t\t\t\t<\/div>\n\t\t\t\t\n\t\t\t\t\t\t\t\t\t<div class=\"elementor-cta__button-wrapper elementor-cta__content-item elementor-content-item \">\n\t\t\t\t\t<a class=\"elementor-cta__button elementor-button elementor-size-\" href=\"https:\/\/www.metgun.com.tr\/en\/ethics-hotline\/\">\n\t\t\t\t\t\tClick to Report Ethics Violations\t\t\t\t\t<\/a>\n\t\t\t\t\t<\/div>\n\t\t\t\t\t\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t<div class=\"elementor-element elementor-element-bce362e elementor-toc--minimized-on-tablet elementor-widget elementor-widget-table-of-contents\" data-id=\"bce362e\" data-element_type=\"widget\" data-e-type=\"widget\" data-settings=\"{&quot;container&quot;:&quot;main&quot;,&quot;exclude_headings_by_selector&quot;:[],&quot;no_headings_message&quot;:&quot;No headings were found on this page.&quot;,&quot;headings_by_tags&quot;:[&quot;h4&quot;,&quot;h5&quot;,&quot;h6&quot;],&quot;marker_view&quot;:&quot;numbers&quot;,&quot;minimize_box&quot;:&quot;yes&quot;,&quot;minimized_on&quot;:&quot;tablet&quot;,&quot;hierarchical_view&quot;:&quot;yes&quot;,&quot;min_height&quot;:{&quot;unit&quot;:&quot;px&quot;,&quot;size&quot;:&quot;&quot;,&quot;sizes&quot;:[]},&quot;min_height_tablet&quot;:{&quot;unit&quot;:&quot;px&quot;,&quot;size&quot;:&quot;&quot;,&quot;sizes&quot;:[]},&quot;min_height_mobile&quot;:{&quot;unit&quot;:&quot;px&quot;,&quot;size&quot;:&quot;&quot;,&quot;sizes&quot;:[]}}\" data-widget_type=\"table-of-contents.default\">\n\t\t\t\t\t\t\t\t\t<div class=\"elementor-toc__header\">\n\t\t\t\t\t\t<h4 class=\"elementor-toc__header-title\">\n\t\t\t\tPURPOSE OF CODE OF CONDUCT and ANTI BRIBERY AND CORRUPTION POLICY\t\t\t<\/h4>\n\t\t\t\t\t\t\t\t\t\t<div class=\"elementor-toc__toggle-button elementor-toc__toggle-button--expand\" role=\"button\" tabindex=\"0\" aria-controls=\"elementor-toc__bce362e\" aria-expanded=\"true\" aria-label=\"Open table of contents\"><svg aria-hidden=\"true\" class=\"e-font-icon-svg e-fas-chevron-down\" viewBox=\"0 0 448 512\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\"><path d=\"M207.029 381.476L12.686 187.132c-9.373-9.373-9.373-24.569 0-33.941l22.667-22.667c9.357-9.357 24.522-9.375 33.901-.04L224 284.505l154.745-154.021c9.379-9.335 24.544-9.317 33.901.04l22.667 22.667c9.373 9.373 9.373 24.569 0 33.941L240.971 381.476c-9.373 9.372-24.569 9.372-33.942 0z\"><\/path><\/svg><\/div>\n\t\t\t\t<div class=\"elementor-toc__toggle-button elementor-toc__toggle-button--collapse\" role=\"button\" tabindex=\"0\" aria-controls=\"elementor-toc__bce362e\" aria-expanded=\"true\" aria-label=\"Close table of contents\"><svg aria-hidden=\"true\" class=\"e-font-icon-svg e-fas-chevron-up\" viewBox=\"0 0 448 512\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\"><path d=\"M240.971 130.524l194.343 194.343c9.373 9.373 9.373 24.569 0 33.941l-22.667 22.667c-9.357 9.357-24.522 9.375-33.901.04L224 227.495 69.255 381.516c-9.379 9.335-24.544 9.317-33.901-.04l-22.667-22.667c-9.373-9.373-9.373-24.569 0-33.941L207.03 130.525c9.372-9.373 24.568-9.373 33.941-.001z\"><\/path><\/svg><\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<div id=\"elementor-toc__bce362e\" class=\"elementor-toc__body\">\n\t\t\t<div class=\"elementor-toc__spinner-container\">\n\t\t\t\t<svg class=\"elementor-toc__spinner eicon-animation-spin e-font-icon-svg e-eicon-loading\" aria-hidden=\"true\" viewBox=\"0 0 1000 1000\" xmlns=\"http:\/\/www.w3.org\/2000\/svg\"><path d=\"M500 975V858C696 858 858 696 858 500S696 142 500 142 142 304 142 500H25C25 237 238 25 500 25S975 237 975 500 763 975 500 975Z\"><\/path><\/svg>\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t<div class=\"elementor-element elementor-element-3a4382f elementor-widget elementor-widget-text-editor\" data-id=\"3a4382f\" data-element_type=\"widget\" data-e-type=\"widget\" data-widget_type=\"text-editor.default\">\n\t\t\t\t\t\t\t\t\t<h6>1. PURPOSE OF CODE OF CONDUCT and ANTI BRIBERY AND CORRUPTION POLICY<\/h6>\n<p>The Code of Business Ethics and Anti-Bribery and Anti-Corruption Policy \nreflect Metg\u00fcn\u2019s commitment to ethical business practices and its expectations \nof ethical conduct from its employees and business partners. These rules apply \nto Metg\u00fcn, its branches and subsidiaries, senior executives, board members, \nemployees, contractors, subcontractors and suppliers, business partners, \nintermediaries, lobbyists and anyone acting on Metg\u00fcn\u2019s behalf. Regardless of \nthe size and location of the business, Metg\u00fcn\u2019s commitment to these rules is in \nline with all laws and regulations, without violating universal human rights and \nethical values.<br><br>\nThe main principles covered by the Code are described below. It is important \nthat these principles described below within the scope of business ethics are \nnot perceived as restrictive. Although not mentioned here, there may be \nsituations that pose risks, and these situations are managed within the \nframework of the Code.<\/p>\n<h6>2. SCOPE OF BUSINESS ETHICS RULES<\/h6>\n<p>2.1. INDIVIDUAL CODE OF ETHICS<br><br>\nMetg\u00fcn has set high ethical standards for everyone working on behalf of the \nCompany. Individuals must adhere to laws and regulations and comply with the \nrequirements and standards set by Metg\u00fcn in the performance of their duties. <br><br>\nMetg\u00fcn expects its employees to show courtesy and respect during their work. \nEach employee must refrain from any negative behavior that may affect the work \nenvironment, employees or the Company. This includes any form of discrimination, \nharassment, or any other behavior that may make employees feel undervalued, \nthreatened, or harassed. Metg\u00fcn employees, agents and representatives must \nrespect the cultural and traditional requirements of their environment.<br><br>\n2.2. EQUALITY and DIVERSITY<br><br>\nMetg\u00fcn does not allow any employee to be subjected to sexual, physical, \npsychological harassment, pressure or bullying. Harassment is unwanted and \nunrequited behavior in the workplace that harasses, humiliates and hurts \nemployees. Harassment can occur between an employee and his\/her manager, \ncoworkers or between an employee and anyone else in the workplace. If it is not \nreciprocated and unwelcome, the following examples can be examples of harassment:\n<br><br>\n\u2022 Physical contact or sexual demands<br>\u2022 Stalking<br>\u2022 Persistent glances with sexual innuendo<br>\u2022 Persistent verbal abuse or threats<br>\u2022 Persistently interfering with an individual\u2019s work, workspace, belongings or \npersonal materials.<br>\u2022 Jokes, insulting or humiliating comments<br>\u2022 Humiliating or demeaning gestures and hand gestures<br>\u2022 Circulation and display of defamatory visual or written materials in the \nworkplace.<br><br>\nHaving employees with different backgrounds, education and personal development \nis an important asset of Metg\u00fcn. Metg\u00fcn is committed to providing equal \nemployment opportunities to all qualified employees and candidates.<br><br>\nMetg\u00fcn employees must comply with all laws and regulations that prohibit \ndiscrimination based on age, race, gender, ethnic origin, nationality, religion, \nhealth, disability, marital status, sexual orientation, political or \nphilosophical opinion, union membership.<br><br>\nIf an employee is exposed to or observes any abuse, he\/she may report it to the \nHuman Resources Department. The Company undertakes not to take any negative \naction against the employee who reports in good faith. <br><br>\nThe recruitment process is evaluated entirely within the framework of the \ncandidate\u2019s qualifications and characteristics. Wages are determined according \nto the Company\u2019s relevant policies and standards as well as the employee\u2019s \ncontribution to the Company. <br><br>\nMetg\u00fcn respects all individuals without discrimination and actively strives to \nprovide a positive working environment based on equality and diversity. However, \nit may sometimes take positive discrimination to achieve equality and diversity.<br><br>\n2.3. SUSTAINABILITY<br><br>\nMetg\u00fcn acts with the philosophy of \u201cSustainable development is only possible \nwith a sustainable environment.\u201d Metg\u00fcn minimizes the impact of the \nenvironmental aspects of its activities and projects and aims to ensure \nsustainable and innovative development in all areas related to the environment, \nensures efficient consumption of natural resources with effective waste \nmanagement, adopts a management approach that complies with environmental \nregulations in the projects in which it operates. It carries out sustainability \nstudies to ensure the balance between economic growth and environmental factors \nand effectively complies with the studies.<br><br>\n2.4. CONFLICTS OF INTEREST<br><br>\nMetg\u00fcn employees must always be loyal to the Company and act with integrity in \ntheir business dealings. Employees must not provide any advantage to other \ncompanies, organizations or individuals that could be used against the Company. \nIn the performance of their duties, Metg\u00fcn employees shall avoid all \nrelationships that may create or be perceived as a conflict of interest and that \nmay adversely affect their judgment or freedom of action. <br><br>\nMetg\u00fcn employees may not work with or be a client with a a spouse, partner, \nfirst-degree relatives such as biological or adopted children, grandchildren, \nparents, grandparents, siblings or children of siblings, household members, or \nanyone else in whom Metg\u00fcn has a direct or indirect financial interest, without \ninforming the Company, Compliance Officer or managers in advance. They must not \nbe on the board of directors of, or work as an executive in, companies that are \ncompetitors of Metg\u00fcn. In addition, anyone who lives with or is economically \nconnected to the employee is considered a family member. <br><br>\nMetg\u00fcn employees must not engage in any activity or agreement that could \nundermine business integrity and trust. Employees who find themselves in a \nconflict-of-interest situation should contact their immediate supervisor and \ninform the Compliance Officer. <br><br>\nEmployees may not use Metg\u00fcn assets or information obtained through their \npositions for personal gain or to compete with Metg\u00fcn. Any situation that may \ncause a conflict of interest must be reported to senior management.<br><br>\nIn the event that people working on behalf of Metg\u00fcn are employed by other \ncompanies that compete with Metg\u00fcn, this must be notified in writing to Metg\u00fcn \nmanagement without delay and written approval must be obtained. <br><br>\n2.5. RESPECT FOR LAWS AND REGULATIONS<br><br>\nMetg\u00fcn\u2019s reputation is built on its respect for all laws and practices in the \ncountries in which it operates. It is the responsibility of the company and its \nemployees to be aware of the laws and practices in the countries in which it \noperates. Each employee should be aware that violations of laws and practices \nmay result in disciplinary action, as well as civil and criminal lawsuits. <br><br>\nTo achieve high ethical goals, Metg\u00fcn expects compliance with ethical standards \nthat go beyond local laws and practices. In addition, Metg\u00fcn is committed to \nhuman rights and labor laws, health and safety standards, environmental \nprotection, anti-corruption, fair competition, taxation practices and accounting \nstandards. Metg\u00fcn also comply with the principles of the United Nations \nDeclaration of Human Rights, the Organization for Economic Cooperation and \nDevelopment (OECD) and the International Chamber of Commerce (ICC).<br><br>\n2.6. CONFIDENTIALITY<br><br>\nConfidential information includes, but is not limited to, intellectual property \nrights and all kinds of innovations belonging to the Company, as well as \ndatabases, printed communication materials, business processes and business \nplans, business strategies, information on strategic partnerships and partners, \nfinancial information, personnel information, customer lists, price, design, \nmethod information (know-how), specifications, information on potential and \ncustomers and all similar information.<br><br>\nInformation is one of the most important assets that the Company will use to \nrealize its goals. Accordingly, it is the shared responsibility of employees to \nuse information effectively, to share it correctly and to ensure the \nconfidentiality, integrity and accessibility of information in this process.<br><br>\nMetg\u00fcn employees should be aware of what information is commercially sensitive, \nshould not share this information with any competitor within the scope of \ncompetition laws, and should pay utmost attention to these issues in \nbusiness-related settings. As these laws are complex and vary from country to \ncountry, Metg\u00fcn employees should always consult with the Compliance Officer or \nthe Legal Department when in a dilemma. However, Metg\u00fcn employees whose duties \nand positions bring them into frequent contact with competitors or suppliers \nshould familiarize themselves with the different competition laws.<br><br>\nEmployees may not share confidential and non-public information about the \ncompany with unauthorized people for any purpose whatsoever. In accordance with \nthe \u201cclean desk-clean screen\u201d principle, it is important that confidential \ndocuments are not left open on desks, passwords are carefully kept, and \nconfidential information is not discussed in common areas. <br><br>\n2.7. HEALTH, SAFETY, ENVIRONMENT and WORK ENVIRONMENT<br><br>\nMetg\u00fcn provides a safe and healthy working environment in all its operations and \nstrives to implement these standards in every project in which it operates. \nThese standards are set out in the Occupational Health, Safety, Environment \n(HSE) principles and all personnel, subcontractors and suppliers are expected to \ncomply. To reduce the number of accidents to zero, special attention needs to be \npaid to high-risk activities. This approach is supported by intensive training \nfor managers and employees and zero tolerance for deviations from these \nstandards. <br><br>\nMetg\u00fcn aims to reduce, minimize or avoid the environmental impact of its \noperations by demonstrating its commitment to applicable environmental laws and \nregulations wherever it operates. In this respect, relevant local and \ninternational laws, regulations and conventions are followed by Metg\u00fcn. This \ncommitment also applies to Metg\u00fcn\u2019s subcontractors, suppliers and business \npartners. <br><br>\nAs Metg\u00fcn, our primary goal in Health, Safety, Environment is to prevent \naccidents and damage to people or property and to prevent damage to the \nenvironment. To maintain high safety standards, Metg\u00fcn expects all employees to \ntake responsibility for their own safety in and around the workplace. <br><br>\nMetg\u00fcn aims to minimize the environmental impact of its activities by taking \npreventive and sustainable measures to protect the environment. Employees must \nbe familiar with all environmental regulations and ensure that their work \ncomplies with current standards, report situations that may harm the environment \nto the relevant consultants or managers in a timely manner, aim to minimize the \nenvironmental impact of activities within their areas, and use Company resources \nefficiently and sustainably.<br><br>\n2.8. PROHIBITED SUBSTANCES<br><br>\nEmployees are prohibited from being under the influence of any stimulants, \nincluding alcohol, while working for the Company. No one should use or encourage \nothers to use stimulants or alcohol in violation of the rules.<br><br>\n2.9. PRIVACY OF PERSONAL INFORMATION<br><br>\nMetg\u00fcn is committed to respecting the confidentiality and privacy of personal \ninformation. Personal information is requested and stored only for the effective \noperation of the Company or as required by law. In keeping with this principle, \nMetg\u00fcn respects the individual\u2019s right to privacy and does not interfere with \nthe individual\u2019s life outside of work unless it adversely affects the \nindividual\u2019s work performance or the Company\u2019s reputation and business \ninterests. The following basic rules must be followed by all employees or anyone \nacting on behalf of Metg\u00fcn:<br><br>\n\u2022 Metg\u00fcn requires its employees, subcontractors and suppliers, business \npartners, intermediaries, customers and all those who deal with Metg\u00fcn to comply \nwith Metg\u00fcn\u2019s Information Security Policy.<br>\u2022 Confidentiality of personal information is ensured and access to this \ninformation is restricted to authorized people who need it.<br>\u2022 Personal information is only used for specific purposes in a fair and honest \nmanner.<br>\u2022 Personal information collected to fulfill legal, regulatory or business needs \ncannot be kept longer than necessary.<br>\u2022 Be informed about privacy laws when transferring personal information abroad \nand get consultancy on this issue if necessary.<br>\u2022 Care should be taken when using electronic media. Information created and \nstored on computers or other electronic devices may not always be secure or \nconfidential. In addition, due to laws and regulations, this information may be \naccessed, monitored and analyzed without prior notice. <br>\u2022 Employees shall not attempt to obtain personal information without a valid \nreason and access authorization and shall not transmit personal data to anyone \nwithin or outside the Company without ensuring its appropriateness.<br><br>\n2.10. ANTI-MONOPOLY<br><br>\nOne of the basic needs of the international economy is competition. Metg\u00fcn \nbelieves that companies should be able to compete fairly in the international \nmarket.<br><br>\nMetg\u00fcn is aware that violations of competition laws can result in severe \npenalties and may expose its employees to commercial, civil, and public criminal \npenalties and, in some cases, even imprisonment. In addition, there is a high \nrisk that third parties may seek compensation from the Company for violations of \nthese rules. Therefore, every Metg\u00fcn employee must understand these laws and \nwork in compliance with them. Metg\u00fcn employees must not participate in \nagreements with competitors that have the purpose of influencing the bidding \nprocess, sharing markets or customers, or boycotting a customer or supplier.<br><br>\nMetg\u00fcn is always committed to the principles of fair competition. Metg\u00fcn \nemployees must not engage in anti-competitive activities, including in countries \nwhere activities contrary to international competition laws are legal or where \ncompetition laws are not developed.<br><br>\n2.11. TRADE RESTRICTIONS and EXPORT BOYCOTTS<br><br>\nFor business purposes and interests, Metg\u00fcn operates in many different areas and \nmarkets. From time to time, certain local or international laws may impose \nembargoes or other trade bans on services, goods, software or technology. Metg\u00fcn \ncomplies with all boycotts and embargoes imposed by relevant authorities and \norganizations to the extent that they do not conflict with the laws of the \nRepublic of Turkey. Any Metg\u00fcn employee who encounters any legal issue or \ndilemma should consult with the Compliance Officer or Legal Department.<br><br>\n2.12. BUSINESS PARTNERS, SUPPLIERS and SUBCONTRACTORS<br><br>\nBusiness partners, suppliers and subcontractors are expected to comply with \nMetg\u00fcn\u2019s principles. The fulfillment of this expectation is ensured through the \ninclusion of relevant clauses in the agreements and the mutual commitment \nbetween the related parties.<br><br>\nMetg\u00fcn attaches importance to compliance with ethical principles when selecting \nbusiness partners, suppliers and subcontractors. In supplier selection, Metg\u00fcn \navoids any gifts, hospitality or any other favoritism that may distort justice, \nand only works with suppliers, business partners and subcontractors who \nundertake to comply with the principles stated herein and ensures that this \ncommitment is documented in writing. It also periodically conducts due diligence \nevaluations of suppliers, subcontractors, partners and intermediaries acting on \nbehalf of Metg\u00fcn.<br><br>\nIt is forbidden for parties who are employees of Metg\u00fcn or acting on behalf of \nMetg\u00fcn or who have business dealings with Metg\u00fcn to accept gifts or hospitality \nfrom parties involved in tender processes in which Metg\u00fcn participates, or to \nshare confidential business information (bid prices or other commercial \ninformation) of any subcontractor, supplier or business partner with any \nsubcontractor, supplier or partner involved in the same process, except where \nprior approval has been obtained from the Compliance Officer or as permitted \nunder the guidelines set forth in this document.<\/p>\n<p>2.13. USE OF INTERMEDIARIES<br><br>\nIf Metg\u00fcn uses an intermediary, the manager involved in the relationship should \nensure that the reputation, background and capacity of the intermediary is \nadequate by conducting a due diligence. Metg\u00fcn expects intermediaries to act in \naccordance with Metg\u00fcn\u2019s code of ethics. <br><br>\nThe agreement between Metg\u00fcn and the intermediaries must reflect the true, full \nand complete relationship between the parties in writing. The ethical \nperformance of Metg\u00fcn and its intermediaries should be regularly monitored, and \nnecessary improvements should be made over time.<br><br>\n2.14. LOBBYING and POLITICAL ACTIVITIES<br><br>\nLobbying is a special type of intermediation that influences approaches and \ndecisions in the public and private sectors. Lobbying can only take place if the \nlobbyist clearly states that he or she represents Metg\u00fcn and intends to \ninfluence the other party\u2019s opinion. This obligation must be clearly stated in \ncontracts with lobbyists. <br><br>\nMetg\u00fcn does not support politicians or political parties and does not make \npayments to political parties, organizations or their representatives. <br><br>\nEmployees are free to participate in democratic political activities but must \nnotify the Compliance Officer in advance and these activities must be conducted \nwithout reference to Metg\u00fcn and without using Metg\u00fcn resources. <br><br>\n2.15. PREVENTION OF MONEY LAUNDERING<br><br>\nMetg\u00fcn does not allow its resources to be used by individuals and entities to \nlaunder money and make these illicit funds appear legal. Failure to show the \nforensic source of money or property, even if it is involved in legal \nactivities, can sometimes be attributed as a crime. Money laundering also \nincludes the use of legal funds for terrorism or crime.<br><br>\nMetg\u00fcn never aids, abets or condones money laundering. Metg\u00fcn always complies \nwith anti-money laundering laws, takes all possible precautions and questions \nthe merit of the parties involved, and always works with reliable and reputable \nsubcontractors, suppliers and business partners to ensure that the source of the \nmoney is reasonably traceable.<br><br>\nMetg\u00fcn, its branches or subsidiaries, lobbyists, senior executives, board \nmembers, employees, contractors, agents, and anyone acting on behalf of Metg\u00fcn \nare responsible for payments made by the company, particularly payments to \nsubcontractors, suppliers, or business partners engaged in questionable \nactivities, and must ensure that such payments do not involve any improper \ntransaction. If any payment is, or is suspected to be, inconsistent with these \nrules, employees must report it directly to their superiors and the Compliance \nOfficer.<br><br>\nWithout the approval of their superiors and the Compliance Officer, Metg\u00fcn \nemployees must never; make payments to people who are not legally entitled to \nreceive the funds or who are not a party to the transaction, receive payments \nfrom people who are not legally entitled to receive the funds or who are not a \nparty to the transaction; accept cash in hand despite the existence of a secure \nbanking system, make shipments to customers that are inconsistent with Metg\u00fcn \nregulations; or conduct foreign exchange transactions with unauthorized \nentities.<\/p>\n<h6>3. BASIS FOR FIGHTING BRIBERY and CORRUPTION<\/h6>\n<p>Metg\u00fcn carries out its activities within applicable sectoral methods and \nrules. Metg\u00fcn attaches utmost importance to business ethics and fair \ncompetition. For this reason, Metg\u00fcn does not tolerate any violation of the \nanti-bribery and anti-corruption principles set forth in these regulations. \nMetg\u00fcn branches and subsidiaries, senior executives, board members, employees, \ncontracted employees, subcontractors and suppliers, business partners, \nintermediaries, lobbyists, and anyone acting in concert with Metg\u00fcn must comply \nwith these rules.<br><br>\nAnti-corruption laws exist in almost every country and their purpose is to \nprevent bribery and similar practices. Violation of these laws can result in \nheavy fines for the company and imprisonment for individuals. The mere suspicion \nor implication of violating these laws, whether locally or internationally, may \nbe enough to damage Metg\u00fcn\u2019s reputation and put its employees at risk, and \nshould be reported to the Compliance Officer and Legal Department as soon as it \nis discovered.<br><br>\nBribery occurs when an attempt is made to influence the performance of a \nperson\u2019s job in order to gain an unfair advantage. Influenced business occurs \nwhen an improper advantage is given to a person in order to influence the \nbusiness of a third party. This may include cash payments, commodities, loans, \ncredits, discounts, travel, hospitality and services. <br><br>\nCorruption is improper and unethical behavior in the decision-making process due \nto a change in the consent of the decision-maker in exchange for a reward or the \nexpectation of a reward. Influencing the consent of the decision maker is never \nconsidered a pretext and is strictly prohibited by this Code.<br><br>\nA Metg\u00fcn employee is prohibited from making promises or conditions to another \nperson that could provide a monetary or other advantage, improperly obtain a \njob, reward a decision, or obtain a resource. A Metg\u00fcn employee may not respond \nto a request for the same purpose. This improper advantage also applies if the \nimproper advantage comes directly or indirectly in the form of a request for \nassistance from a third party, or a request for assistance from an agent, \nsupplier, subcontractor, joint venture or affiliate. <br><br>\nThe subject of the prohibitions may be any public official, political party, \nagent or employee of a public or private client, or a lending institution or \nbank. Public officials include, but are not limited to, public or government \nofficials, agents, employees or representatives; any political party or \npolitical party officials, agents, employees or representatives; any candidate \nfor public office or political party; members of public organizations; officers \nor employees of international organizations; international judges or their \nemployees; and finally, employees of companies under government control or owned \nentities.<br><br>\nIt is strictly forbidden for a Metg\u00fcn employee to accept a bribe or receive any \nbenefit of any kind in return for making a decision that would provide a \nmonetary or other advantage to a third party. The same prohibitions that apply \nto bribery and influence peddling apply to both the offeror and the acceptor. \nSuch a request or offer is sufficient evidence of impropriety. It is not a \nprerequisite for the occurrence of a situation in which an improper advantage is \ntaken that the person intending to take advantage of it carries it out.<br><br>\nMetg\u00fcn may be held liable for bribery or any other wrongdoing by third parties \nengaged by Metg\u00fcn, such as suppliers or subcontractors. Thus, Metg\u00fcn expects \nthird parties with whom it does business to take risk mitigation measures \nagainst bribery and corruption.<br><br>\nFacilitating payments are payments made by legal channels to expedite mandatory \nadministrative regulations and formalities. While such payments are tolerated in \nsome countries, they are illegal. Metg\u00fcn prohibits such payments in principle.\n<br><br>\nMetg\u00fcn will not impose penalties or sanctions on any of its employees, even if \nthey suffer job loss or damage to their trade name, for complying with \nanti-bribery and anti-corruption principles.<br><br>\n3.1. GIFTS, MEALS and ENTERTAINMENT<br><br>\nThe Company aims to ensure that business decisions made by Company employees, \nsubcontractors, subcontractors or suppliers, business partners, intermediaries, \nlobbyists and anyone else who may act with Metg\u00fcn do not result in any personal \ngain or conflict of interest. Gifts or entertainment of any kind cannot be given \nto influence a business decision or to gain an advantage. The same applies to \nreceiving gifts or entertainment.<br><br>\nMetg\u00fcn employees must not allow their family members or relatives to accept \ngifts, money, loans, invitations or similar offers of special treatment from \npeople who have a business relationship with Metg\u00fcn in order to influence \nbusiness decisions and must not allow their family members or relatives to make \nsimilar offers to such people. For this reason, Metg\u00fcn employees and those \nacting on Metg\u00fcn\u2019s behalf must not accept any gift, directly or indirectly, \nexcept for promotional items with the company logo on them and of minimal or \ninsignificant value. In cases where refusal would be misunderstood, the gifts \nreceived shall be immediately returned to Metg\u00fcn and the gift shall be treated \nas Metg\u00fcn\u2019s property.<br><br>\nOffers of hospitality, such as social events or meals, are acceptable where \nthere is an open and fair business relationship. The cost of the entertainment \nshould be kept as low as possible and information about the people entertained \nshould be documented. For Metg\u00fcn employees, travel, accommodation and similar \nexpenses that may be incurred during such entertainment must be paid by Metg\u00fcn. \nIn order to provide or benefit from gifts, hospitality and similar advantages, \nprior approval must be obtained from the senior manager. Therefore, the \nfollowing rules should be considered and applied: <br><br>\n\u2022 An act of business courtesy may only be offered or accepted for a lawful \npurpose.<br>\u2022 It must be based on a valid employment relationship justification.<br>\u2022 It must comply with Metg\u00fcn\u2019s Code of Business Ethics and Anti-Bribery and \nAnti-Corruption Guidelines.<br>\u2022 Acts of business courtesy provided to or by staff must not have occurred too \nfrequently when considered in aggregate with other acts of business courtesy in \na given period. Employees are required to consult with the Compliance Officer in \nadvance if they have engaged in or participated in acts of business courtesy \nmore than six times in the last twelve-month period,<br>\u2022 The act of business courtesy must not be done secretly by other employees of \nthe Company or related people. The act of business courtesy must not be \nextravagant or wasteful and must be kept within reasonable limits.<br>\u2022 Gifts in cash or cash equivalents (such as gift certificates) should never be \npermitted.<br>\u2022 Must comply with limits. Acts of business courtesy above monetary limits are \nsubject to written approval by the General Manager before being offered or \naccepted. For gifts and acts of business courtesy, the limits for \ngiving\/receiving and the people for whom approval is required are specified \nseparately.<br>\u2022 Travel, accommodation and other expenses of Metg\u00fcn personnel must always be \npaid by the Company.<br>\u2022 In all acts of gift and business courtesy, the form must be filled out and \napprovals must be obtained. The completed form should be sent to the Compliance \nOfficer and information should be provided.<br><br>\n3.2. APPROACH TO PUBLIC OFFICIALS<br><br>\nMetg\u00fcn does not authorize any direct or indirect payments, in cash or otherwise, \ngifts, promises or other advantages, and does not authorize any gifts, benefits \nor promises to any public official, political party or third party, ta an \nimmediate family member of an intermediary or an agent, either directly or \nthrough an intermediary, that would constitute a violation of the law. <br><br>\n\u201cImmediate family members\u201d include spouses, partners, children (biological or \nadopted), grandchildren, parents, grandparents, siblings, spouses and children \nof siblings, or any household member. Payments made by a distant relative to any \ngovernment official can therefore also be criminalized. <br><br>\nThese include, but are not limited to, the UK Bribery Act 2010, the US Foreign \nCorrupt Practices Act (FCPA), OECD anti-bribery of foreign public officials, UN \nanti-corruption conventions or anti-money laundering, anti-corruption or \nanti-conflict of interest laws in the countries where Metg\u00fcn operates. Metg\u00fcn \nshould never do business with anyone who has broken anti-corruption laws.<br><br>\nIn light of the foregoing, Metg\u00fcn employees, officers, branches and \nsubsidiaries, as well as its subcontractors, suppliers and business partners, \nmust not give or receive gifts, money, bribes or kickbacks, or anything of \n\u201cvalue\u201d that creates unrecorded assets for the purpose of directing business \ndealings or for any other reason. The term \u201cof value\u201d includes goods, services \nand non-cash benefits or advantages. <br><br>\nIt also includes, but is not limited to, cash or cash equivalents, the \npurchase\/sale of real estate, services at inflated or reduced prices, \nhospitality, cars, jewelry, household goods, travel, debt, securities or shares. \nSomething of value can also apply to benefits that have no material value. \nExamples include insider information, stock tips, or illegally arranging or \nfacilitating the arrangement or conclusion of a transaction.<br><br>\nDue care must be exercised when dealing with public officials. Metg\u00fcn does not \nallow any gift, payment or anything of value to be offered to public officials \nthat is not covered by this Code. <br><br>\n3.3. SOCIAL AID, CHARITY WORKS and POLITICAL AID<br><br>\nCharitable contributions are contributions to charitable, educational, \nscientific or artistic organizations under the guise of charity. Although social \nand charitable contributions are legal and accepted by the international \nbusiness community, they should be carefully scrutinized for the risk of \ncorruption. Under no circumstances may a social or charitable contribution be \nmade on behalf of the Company to influence an organization, a political party \nand in particular a public official, to make or withdraw a decision.<br><br>\nIn all circumstances, a \u201cIntegrity Due Diligence\u201d must be conducted by the \nCompany to ensure that a social or charitable contribution does not directly or \nindirectly benefit a public official personally.<br><br>\nAll social and charitable contributions must be based on a written contract that \nincludes Metg\u00fcn\u2019s contributions, the contributions of other participants, the \npurpose and benefits of the project, milestones, timeline and costs. The \ncontract must include anti-corruption clauses and must be approved by the \nCompliance Officer and the Legal Department with the necessary audit clauses.<br><br>\nMetg\u00fcn, its employees, officers, agents, branches and subsidiaries, as well as \nits subcontractors, suppliers and business partners, including agents, lobbyists \nand all employees acting through Metg\u00fcn, must not make any political \ncontributions or support any political person or party.<br><br>\nDonations and social assistance should only be made to organizations, public \ninstitutions or eligible individuals that inspire confidence that the donation \nor assistance will be used in line with the objectives of the Code of Business \nEthics. For this reason, a detailed examination should be made about the \norganization to be donated to, and possible \u201cred flags\u201d should be evaluated. For \ndonations to public institutions, donations or social assistance should not be \nmade in cases where a public official may personally benefit from the donation \nor social assistance.<br><br>\nNecessary documents and records related to donations and social assistance must \nbe kept, and the relevant form must be prepared by the requesting Metg\u00fcn staff \nand approved by the manager. Donations and social contributions must not be made \nin cash and must be accurately reflected in the accounting accounts. <br><br>\n3.4. CASH PAYMENTS<br><br>\nMetg\u00fcn has defined methods for controlling, recording and reporting cash \nmovements. In principle, every transaction is controlled, recorded and reported. \nThe uncontrolled use of petty cash carries a high risk of corruption. To \nmitigate this risk, Metg\u00fcn has created a reliable control mechanism over the use \nof cash and related accounting records.<br><br>\nCash payments should only be used when electronic payment or bank transfers are \nnot possible. All cash payments should be recorded in the accountancy account \nregardless of their monetary value and should be compared with the original \ninvoices that clearly show the purpose of the expenditure.<br><br>\nAll cash expenses must be recorded with the original receipt or invoice.<\/p>\n<h6>4. LIABILITY FOR COMPANY ASSETS<\/h6>\n<p>4.1. ASSET PROTECTION<br><br>\nEvery Metg\u00fcn employee has a responsibility to ensure that Company assets are not \nmisused or wasted. Company assets consist of physical property as well as time \nsheets, proprietary information, company facilities, company funds and company \nmaterials. Metg\u00fcn employees must, at all times;<\/p>\n<p>\u2022 Ensure that goods and property used or accessed are not damaged, misused or \nwasted.<br>\u2022 Protect the Company\u2019s confidential and proprietary information, proprietary \ninformation and intellectual property rights. Use these assets for their \nintended purpose. They must not use Company assets for their own personal \nbenefit or for the benefit of anyone other than Company employees.<br>\u2022 Theft of the Company\u2019s products and equipment, theft or misappropriation of \ninformation, embezzlement through manipulation of time and expense reports may \nresult in termination of employment and criminal prosecution. The Company \napplies the same sanctions to theft among its employees as it applies to theft \nof Company assets. <br>\u2022 Written approval from the Compliance Officer is required for the employee to \nuse Company assets outside of work (such as the use of Company property outside \nof work or the use of Company material for personal gain). <br>\u2022 The employee must not engage in personal activities during working hours that \nmay prevent him\/her from fulfilling his\/her responsibilities.<br>\u2022 Employees must not engage in commercial or legal\/unethical activities (such as \ngambling, watching pornography) that are not related to work using Company \ncomputers and equipment.<br>\u2022 The employee should not use his\/her position in the Company, or the \nacquisitions obtained through the Company\u2019s assets and information to obtain \nfinancial gain. <br><br>\nExamples of company assets include money, fixed assets, time spent, or products \nproduced by employees, computer systems and software, telephones, wireless and \nmobile communication devices, photocopiers, printers, company vehicles, property \ninformation, company trademarks.<br><br>\n4.2. ACCURATE INFORMATION, ACCOUNTING and REPORTING<br><br>\nInvestors, creditors and other stakeholders have a legitimate interest in \nMetg\u00fcn\u2019s financial accounting and reporting. The reliability of financial \naccounting and reporting depends on the accuracy, completeness and timeliness of \naccounting records. Therefore, Metg\u00fcn reports company information accurately, \nobjectively and honestly. This information includes financial and non-financial \nrecords and reflects any information, transactions and events that are created \ncorrectly. These reports include financial data as well as other information \nsuch as HSE performance information or HR records. <br><br>\nMetg\u00fcn complies with all applicable laws and regulations in terms of record \nkeeping, identification and, where necessary, reporting. Metg\u00fcn\u2019s principle is \nto be honest, open and transparent at all times about its operations and the \nperformance and results of its operations. All financial transactions must be \nfully and completely recorded in Metg\u00fcn\u2019s accounting records. <br><br>\nAt no time should employees conceal, alter or destroy property or information \nrelated to Metg\u00fcn\u2019s involvement in a lawsuit, government or regulatory \ninvestigation. This requirement also applies to litigation or investigations \nthat may arise in the future. <br><br>\n4.3. INFORMATION and INFORMATION TECHNOLOGY SYSTEMS<br><br>\nThe records kept in Metg\u00fcn\u2019s Information Technology (IT) systems are considered \nMetg\u00fcn\u2019s own property. Metg\u00fcn therefore has the right to access all such \ninformation unless prohibited by law or agreement. <br><br>\nThe employee is responsible for keeping his\/her electronic files and archives in \norder. Private use is permitted on a limited basis. Illegal, disturbing and \ninappropriate content, illegal, disturbing and\/or obscene photos, messages or \nfiles should not be downloaded, stored or published. Metg\u00fcn fully complies with \nthe necessary rules against copyright problems that may arise in written \nmaterials, photographs and software within the framework of intellectual and \nindustrial rights. For this reason, it is forbidden to download, store or \npublish anything that violates intellectual and industrial rights.<\/p>\n<h6>5. ORGANIZATION, RESPONSIBILITIES, EXECUTION, IMPLEMENTATION<\/h6>\n<p>5.1. ORGANIZATION<br><br>\nThe Code describes the basic principles of behavior expected of employees, \nsubcontractors, suppliers and business partners doing business with Metg\u00fcn. It \nis the responsibility of the Board of Directors to ensure that the Company\u2019s \nemployees are aware of the Code and that the Code is sustainable. The Board of \nDirectors appoints a Company Compliance Officer and Compliance Committee.<br><br>\nThe Compliance Committee, together with the Compliance Officer, reports to the \nBoard twice a year on implementation and any necessary changes are discussed \nthere.<br><br>\n5.2. RESPONSIBILITIES<br><br>\nEach employee must familiarize himself\/herself with the Code and applicable laws \nand regulations and perform his\/her duties in compliance with them. <br><br>\nEmployees shall sign a declaration acknowledging that they have read and \nunderstood the Code and agree to comply with it and shall make similar \nnotifications on a regular basis. Failure not to sign the declaration will not \nexcuse non-compliant behavior. <br><br>\nManagers are responsible for ensuring that the activities in their areas of \nresponsibility are within the framework of the rules written in this document. \nManagers are responsible for communicating the rules written here to employees \nand guiding employees in the application and interpretation of these rules.<br><br>\n5.3. COMPLIANCE COMMITTEE and COMPLIANCE OFFICER<br><br>\nThe Company, through the Board of Directors, appoints a Compliance Officer and \nCompliance Committee to ensure and monitor the implementation of the Code of \nBusiness Ethics and Anti-Bribery and Anti-Corruption Policy.<br><br>\nThe Compliance Committee reports directly to the Board of Directors. The \nCompliance Committee, together with the Compliance Officer, should report to the \nBoard of Directors every six months on the implementation of these rules and \npossible improvements and updates.<br><br>\nAny guidance or regulations developed and issued by the Compliance Committee and \napproved by the Board of Directors must be implemented by all those affected by \nthese rules.<br><br>\n5.3.1. Compliance Committee<br><br>\nThe Compliance Committee consists of a Board Member, Chief Legal Counsel and \nCompliance Officer. Chairman of the Committee is the Board Member.<br><br>\nThe Compliance Committee assists the Board of Directors in overseeing the \nCompany\u2019s corporate responsibilities and compliance efforts in its fields of \nactivity. The Committee holds regularly scheduled meetings at least two (2) \ntimes a year. In addition, the Committee convenes regularly on issues that the \nmembers request to be discussed separately and privately. The Committee may hold \nmeetings with other executives of the Company from time to time if deemed \nappropriate by the Chairman. <br><br>\nThe Committee will keep meeting notes and records with the Compliance Officer \nand records of its other activities, and the Committee\u2019s meeting notes will be \ndistributed to all members. <br><br>\nThe Committee is responsible for monitoring the fact that the Company\u2019s \nactivities are carried out in accordance with and in compliance with the Code \nwithin the framework of sectoral and international standards, legal business \nlife trends and public policies. The Committee may make appropriate \nrecommendations regarding the implementation of these rules, including but not \nlimited to the following:<br><br>\n\u2022 To provide the Compliance Officer with the necessary and sufficient monetary \nand other resources and personnel to fully fulfill his\/her responsibilities.<br>\u2022 Ensuring the implementation of the written rules and regulations guiding the \nCompany and the guidance of the office and other employees in accordance with \nthem in their daily business processes, training of the Company\u2019s public \npractices, activities related to governmental affairs, including political \nsupport, and training of responsible business partners, members of the Board of \nDirectors and managers, office staff and employees and other business partners \nof the Company who provide support for the Company\u2019s charitable activities.<br>\u2022 Determining the efficiency of the Company\u2019s compliance efforts and related \nrisks on a regular basis.<br>\u2022 Monitoring and auditing of the Company\u2019s processes and transactions.<br>\u2022 Investigate reported incidents of non-compliant and erroneous behavior.<br>\u2022 Improve standards through disciplinary measures and incentives.<br>\u2022 Making necessary revisions to the written rules.<br>\u2022 Developing an ethical culture.<br><br>\nThe Compliance Officer will report to the Committee the information on \nsignificant non-compliant practices that may affect the Company. In addition, \nthe Compliance Officer will report to the Chairman of the Committee any \nsignificant non-compliance information regarding the Company\u2019s employees. The \nCommittee will review the rules on a regular basis and, when necessary, submit \nits recommendations for amendments to the Board of Directors.<br><br>\n5.3.2. Compliance Officer<br><br>\nThe duties and responsibilities of the Compliance Officer include, but are not \nlimited to, the following:<br><br>\n\u2022 Monitoring the preparation and publication of regulations to guide employees \nin the face of specific legal and regulatory obligations, compliance clauses and \nsituations affecting ethical business conduct.<br>\u2022 Preparing materials, documents and updating proposals for the Company\u2019s \nethical business rules and submitting them to the Compliance Committee, \norganizing training for all stakeholders to ensure that these rules are \nunderstood and kept in mind.<br>\u2022 Identifying internal and external corruption risks that the company may face.<br>\u2022 Conduct an annual efficiency assessment of the Company\u2019s anti-corruption \nprogram; through the assessments, demonstrate how well the Company is \nimplementing relevant policies and regulations at the time of operations.<br>\u2022 Investigating violations of the Code or inappropriate activities or following \nup on existing investigations.<br>\u2022 Assist in conducting the Due Diligence on intermediaries, subcontractors, \nsuppliers, and observe Metg\u00fcn\u2019s compliance process and obtain external \nassistance if necessary.<br><br>\n5.4. INTEGRITY DUE DILIGENCE<br><br>\nEvery relationship or agreement with a third party is a source of risk because \nof the possibility that third parties acting on Metg\u00fcn\u2019s behalf may, directly or \nindirectly, incur legal liability and\/or reputational damage. Because of the \nrisk of harm when individuals or companies act on Metg\u00fcn\u2019s behalf, the Company \nmust make every effort to compel these individuals and companies to adhere to \nethical standards. For the avoidance of doubt, the definition of \u201cthird party\u201d \nincludes all business partners, operators, subcontractors, suppliers, \nintermediaries, agents, lobbyists, customers and anyone else acting on Metg\u00fcn\u2019s \nbehalf.<br><br>\nIn order to establish or change a business relationship with a third party, that \nparty must comply with the requirements of Metg\u00fcn\u2019s Due Diligence. The review is \nconducted to prevent Metg\u00fcn from entering into a relationship that involves any \ntransparency issues, conflicts of interest or \u201cred flags\u201d and prevents Metg\u00fcn \nfrom doing business with corrupt parties. Otherwise, Metg\u00fcn may be associated \nwith illegal or unethical parties. The Compliance Officer develops and \nimplements relevant guidelines in connection with the due diligence. Examples of \nred flags are included in Annex 1.<br><br>\nThe scope of the Integrity Due Diligence depends on the risk status of the \ntransaction or party in question. Every Metg\u00fcn employee should be alert to the \npossibility of a red flag of corruption or compliance risk. The Compliance \nOfficer must be involved in the preparation and sign-off of each review report, \nwhich will include the results of the review and recommendations for \nimprovement, if necessary. The Compliance Officer should assess the existing \nrisks on a new or ongoing agreement with a third party and report to the Board \nof Directors through the Compliance Committee with recommendations.<br><br>\nAgreements with parties must include all provisions necessary to comply with \napplicable laws and Metg\u00fcn\u2019s ethical requirements. The Compliance Officer should \nwrite\/review and keep the anti-corruption provisions up to date. Significant \nchanges to these provisions must be approved by the Compliance Committee. <br><br>\n5.4.1. Identification of Companies to be Evaluated <br><br>\nWhen working with third parties, it is critical to conduct sufficient due \ndiligence to understand the third party\u2019s experience, true owners and \nreputation. When selecting third parties, Metg\u00fcn places a high level of \nimportance on their compliance with ethical principles. Metg\u00fcn promotes its \nethical principles to partners, subcontractors and suppliers doing business with \nMetg\u00fcn and only works with companies that commit to abide by Metg\u00fcn\u2019s Code of \nBusiness Ethics. This is also stated in contracts and purchase orders.<br><br>\nIt is neither possible nor necessary to eliminate all ethical\/compliance risks \nthat a third party may pose. It is also unrealistic to scrutinize all third \nparties to the same degree, as not all third parties pose the same level and \ntype of risk.<br><br>\nIf the main contract (or expected contract amount) or purchase order amount (or \nexpected annual PO amount) or the total amount of different contracts\/purchase \norders of the third party at the relevant location) is above the limit of 50,000 \nUSD, then for these companies, due diligence is carried out. <br><br>\nInternet searches are conducted through a variety of sources, including global \nsanctions lists, public records, negative news checks, checks on legal \ndatabases, third-party litigation history, use of specialized databases, credit \nchecks, lists of \u201cprohibited and disqualified companies and people\u201d published by \nregulatory agencies, and lists of \u201cpolitically exposed people (PEPs)\u201d. <br><br>\n5.4.2. Evaluation Method<br><br>\nOnce third parties are determined to be \u201cin scope\u201d, the next step is to \ninvestigate the risk identified in the preliminary assessment in detail across \ndifferent channels and determine the level of risk. <br><br>\nPrior to the assessment, a Company Due Diligence Questionnaire Form is sent to \nthird parties requesting the company\u2019s statement and supporting documents on \nissues such as company structure, ethics\/compliance management system, labor law \n&amp; human rights compliance, possible conflict of interest, possible legal \nproceedings related to the company, relations with third parties and government \nagencies, gift and donation practices, personal data privacy practices, money \nlaundering, terrorism financing. Sending and following up the questionnaire is \nthe responsibility of the department that establishes the relationship with the \ncompany. The incoming questionnaire must be initialed with the company stamp and \nauthorized manager signature on each page. <br><br>\nThe accuracy of the incoming information is evaluated by using the preliminary \nassessment information and the risk level of the third party is determined. This \nassessment is made by the Compliance Officer, and support is obtained from the \nLegal Department in legal matters. The result of the assessment is recorded in \nthe Third Parties Ethics &amp; Compliance Due Diligence Decision Form. The risk \nlevel of the company is assessed as \u201chigh\u201d, \u201cmedium\u201d, \u201clow\u201d or \u201cno risk\u201d. The \nrisk assessment should be documented with a reasonable number of evidence \ndocuments.<br><br>\nIdentifying risks in the assessed issues does not mean that the business \nrelationship with the third party will not continue. Measures to reduce the \nlevel of risk identified can be implemented.<br><br>\nThe approval and post-approval processes require strong collaboration between \nthe department wishing to engage with the third party, the relevant headquarters \ndepartment and the Compliance Department. Once the risk assessment and due \ndiligence processes are completed, approval must be obtained to decide whether \nto proceed with the third party. Approval of the business relationship with low \nand medium risk third parties involves the Legal Department Manager, the manager \nof the department entering the business relationship, the manager of the \nrelevant head office department and the Compliance Officer. For high-risk third \nparties, in addition to these departments, the approval of the General Manager \nmust also be obtained.<br><br>\n5.4.3. Monitoring<br><br>\nDue diligence assessments are updated in accordance with the following timetable \nas of the date of the assessment, based on the identified risk category.<\/p>\n<p>RISK LEVEL UPDATE<br><br>\nHigh Risk Every 6 months<br><br>\nMedium Risk Every 1 year<br><br>\nLow Risk Every 2 years<\/p>\n<p>The following monitoring activities should also be implemented to mitigate \nthe identified risk in business relationships with medium and high risk third \nparties.<br><br>\n\u2022 Detailed review of third-party payment claims and progress payments<br>\u2022 Obtaining the third party\u2019s annual declaration of compliance with applicable \nanti-corruption laws<br>\u2022 Providing training to company managers and employees on ethics &amp; compliance<br>\u2022 Periodic renewal or updating of risk assessment processes<br>\u2022 Periodic and\/or risk-based audits of third parties<br>\u2022 Adding additional ethics &amp; compliance clauses to contracts<\/p>\n<p>5.5. RISK ASSESSMENT and REPORTING<br><br>\nAt least once a year, the Compliance Officer assesses the external corruption \nrisks to which Metg\u00fcn may be exposed (e.g. arising from business transactions or \nbusiness partnerships and internal corruption risks, including non-compliance \nwith anti-corruption policies and regulations). Based on this assessment, the \nCompliance Officer prepares a report to be submitted to the Board of Directors \nthrough the Compliance Committee. The report includes the internal and external \ncorruption risks that Metg\u00fcn may face and the measures that can be taken to \neliminate them.<br><br>\nMetg\u00fcn establishes an anti-corruption compliance assessment program to be \nconducted on a regular basis by the Compliance Officer. The purpose of this \nassessment is to regularly review the anti-corruption policies and regulations \nand examine how these policies and regulations are implemented within Metg\u00fcn\u2019s \noperations.<br><br>\n5.6. COMMUNICATION<br><br>\nThe Code has been shared with all employees and is also available on Metg\u00fcn\u2019s \ninternal network and the web page. The Code is communicated during employee \norientation, internal communications and classroom training.<br><br>\nIn order to ensure effective communication with external parties, inquiries \nabout Metg\u00fcn or its employees should be directed to the relevant communication \nunit or the Compliance Officer. <br><br>\nEmployees making press releases must act in accordance with the above \nrequirements. Employees should not make statements about the Company\u2019s financial \nresults, prospective financial performance or business activities unless \nspecifically instructed to do so. Employees must ensure that Metg\u00fcn or its \nshareholders are not harmed by any outside source of communication. It must be \nrecognized that violations of the rules governing the disclosure of non-public \ninformation may expose both themselves and the Company to legal sanctions.<br><br>\n5.7. HANDLING CASES of DOUBT AND BREACHES of CODE<br><br>\nAll employees must immediately report any possible violation of the Code. \nSuspected violations may be reported to the employee\u2019s manager, the manager\u2019s \nmanager, the Compliance Officer, the Compliance Committee or any member of the \nBoard of Directors, or other reporting mechanisms established by the Company may \nbe used. Metg\u00fcn undertakes that no action will be taken against the person \nmaking a report in good faith. All reports and notifications must be followed up \nby the Compliance Officer and taken seriously. If reports are not made \nanonymously, the Compliance Officer and the Compliance Committee shall keep the \nsource of the report confidential. <br><br>\nAny manager who receives a report involving a violation of anti-corruption laws \nand regulations must promptly forward it in writing to the Compliance Officer.\n<br><br>\nAll employees should raise valid concerns in good faith. There must be no \nsuspicion or fear that they may be sanctioned, even if these concerns are raised \nin good faith but turn out to be unfounded. Notification should be made when the \nfollowing violations or hazards are believed to exist:<br><br>\n\u2022 Violation of Metg\u00fcn Code of Business Ethics and Anti-Bribery and Anti-Corruption \nPrinciples<br>\u2022 Behavior that could discredit Metg\u00fcn<br>\u2022 Criminal activities<br>\u2022 Endangering health and safety<br>\u2022 Failure to comply with any legal or professional obligation<br>\u2022 Bribery<br>\u2022 Performing an act that is likely to cause harm to employees.<br>\u2022 Damage to the environment<br>\u2022 Unlawful disclosure of confidential information.<br><br>\nIf an employee has a valid suspicion or concern that any improper behavior, \nincluding any of the above, has occurred, he or she must report it. If an \nemployee is in doubt as to whether a matter is reportable, he or she should \nconsult with the Compliance Officer.<br><br>\n5.7.1. Principles for Raising Concern<br><br>\nThe aim of the Company management and the Compliance Officer is to ensure that \nemployees are aware of the following issues and report their concerns:<br><br>\n\u2022 The notification must be made with honesty, integrity and in good faith.<br>\u2022 The notification must be in sufficient detail to enable the necessary \ninvestigation to be carried out effectively.<br>\u2022 If an employee makes a report knowing it to be false or unfounded or makes \nuntrue allegations in bad faith or for personal gain, they will be subject to \ndisciplinary action.<br>\u2022 The review of the notification shall be conducted under the strictest \nconfidentiality.<br>\u2022 While it is expected that reports will mostly concern the actions of Metg\u00fcn \nemployees, they may also concern the actions of business partners. Therefore, \nindividuals who have a valid reason to be concerned about violations of the Code \nof Business Ethics by business partners are encouraged to share their concerns.<br>\u2022 Metg\u00fcn undertakes that no sanctions will be imposed on, or considered \ndetrimental to, any person who informs authorized people, company units or other \nauthorities in the company about possible violations of the company\u2019s code of \nethics, laws or other rules.<br>\u2022 Notices may be made by subcontractors, suppliers, business partners, agents or \nany other person, other than employees.<br><br>\n5.7.2. How to Report Concern<br><br>\nNormally, an employee\u2019s complaint should be addressed to the manager of the \nrelevant department to ensure that the chain of authority is followed. In this \nway, the matter will reach the senior management of the relevant department. \nSenior managers are obliged to transfer ethics and compliance notifications to \nthe Compliance Officer. Employees may report directly to the Compliance Officer \nif they prefer or if their reports are related to their manager(s).<br><br>\nNotifications can be made face-to-face, by phone, e-mail, or through web page. \nNotifications and documents to support the notification can be sent to the \ne-mail address etik@metgun.com.tr. Notifications of breach of ethical rules can \nbe made via the \u201cEthics Line\u201d to +90 (212) 3582010 ext. 1454. <br><br>\nEmployees or others can file an anonymous complaint (silent mechanism) through \nweb page. However, for anonymous complaints to be investigated effectively, the \nmatter must be explained in detail. One of the main criteria for deciding is \nwhether sufficient information is available for investigation. If the \ncomplainant has given his or her name, the identity of the person making the \ncomplaint will be kept confidential within the framework of this Code in the \ninterests of honesty, fairness and openness. However, if for any reason the \ncomplainant feels uncomfortable using the usual complaint reporting channels, \nhe\/she may also submit his\/her complaint directly to the Compliance Officer. The \nCompliance Officer and the Compliance Committee will honor the person\u2019s request \nfor anonymity within the framework of these rules.<br><br>\n5.7.3. Review and Reporting of Notification<br><br>\nFactors such as confidentiality concerns, potential legal proceedings, potential \nproblems due to actual or alleged ethical or illegal violations, and potential \nreputational damage can make the process challenging and complex. By its very \nnature, this process involves accusations or allegations against employees \nwithin the company. <br><br>\nThe review of the notification is carried out to determine whether there are \nactions and behaviors defined as ethical\/compliance violations in the \nregulations, to determine the extent of the violation, if any, and to take \nappropriate measures, and to determine the ways to eliminate the damage and \nlosses incurred or potential damage and losses. In addition, the notification \nreview also includes the activities of collecting information and documents from \nrelevant sources within the scope of the review and research carried out to \nprevent the repetition of the actions, and preparing a report to inform the \nrelevant units about the results and conclusions reached.<br><br>\nAll notifications will be shared with the Compliance Officer, who will conduct a \npreliminary review with the support of different departments within the company \nto determine the scope of the issue and the relevant people. The Chairperson of \nthe Compliance Committee, the Compliance Officer and the relevant department \nmanager, depending on the content of the notification, will decide on the path \nto be followed in the evaluation of the notification. <br><br>\nIn order to finalize a notification, the work done must be reported in writing. \nReporting is made to the Compliance Committee and other people deemed \nappropriate by the Committee. Violation of Metg\u00fcn\u2019s ethical values may result in \ndisciplinary action, dismissal with or without warning and, if necessary, \nreporting the situation to the relevant authorities.<br><br>\n5.8. TRAINING<br><br>\nThe Code of Business Ethics and Anti-Bribery and Anti-Corruption Principles \nTraining, which is prepared for all Metg\u00fcn employees, covers the principles of \nMetg\u00fcn\u2019s policies and regulations on business ethics and includes questions and \nanswers. This training is provided to all employees as part of the orientation \nprogram and is repeated annually. It can be applied to managers of \nsubcontractors when necessary.<br><br>\nReminder publications are sent by the Compliance Officer on a regular basis or \nwhen deemed necessary, explaining the content of a subject of the Code of \nConduct and examples of its violation in practice.<br><br>\nCommitment and declaration forms are prepared in which all personnel declare \nthat they have read, understood and accepted all of the regulations.<br><br>\nSuppliers\u2019 purchase orders and subcontractors\u2019 contracts contain a clause in \nwhich they undertake to comply with Metg\u00fcn\u2019s Code of Business Ethics.<br><br>\n5.9. AUDIT and REVIEW OF RULES<br><br>\nCompliance with the Code will be monitored by the Compliance Officer and \nreported to the Board of Directors through the Compliance Committee every six \nmonths.<br><br>\nThe Compliance Officer conducts audits, investigations and reviews to protect \nthe rights and interests of the Company and employees, to develop \nrecommendations against internal and external ethics &amp; compliance risks and to \nprovide reasonable assurance. The Company\u2019s Board of Directors and the General \nManager provide the necessary resources to ensure that the Compliance Officer \nhas sufficient number and quality of personnel, has a suitable working \nenvironment and technical equipment to ensure effective audit activity.<br><br>\nThe Compliance Officer is authorized to access all departments, records, assets, \ninformation, documents, regulations and personnel that may be relevant to the \nsubject matter in annual audits to be conducted or special examinations to be \nassigned. The personnel of the audited department are obliged to provide direct \ninformation about transactions or activities that may cause damage or material \nlosses to the Company. If any level of management prevents access to the \naforementioned information, documents or papers, the next higher-level manager \nmust explain the reasons for such prevention and the Compliance Committee must \nbe informed.<br><br>\nThe Compliance Officer carries out his\/her work within the framework of the \naudit calendar and appropriate programs. The audit schedule is made as a result \nof risk assessments and by considering the requests and suggestions of the \nGeneral Manager. Apart from ordinary audits, no preliminary program is prepared \nfor activities such as investigations, examinations and special audits. <br><br>\nBefore starting the field work, the General Manager and the senior management of \nthe project\/company where the audit will be conducted are informed. At the end \nof the fieldwork, findings, risks and recommendations related to the audited \nfunction\/department\/process are documented. The actions to be taken regarding \nthe findings of the audit are prepared by the audited department and sent to the \nCompliance Officer.<br><br>\nIn addition to the audit reporting made during each visit to the project, the \nCompliance Officer also reports to the Board of Directors every six months on \nthe general scope of work during the year.<br><br>\nMetg\u00fcn reviews this Code once a year and may make additions or changes. Comments \nor suggestions from all employees regarding the Code are welcomed. Employees are \ninformed of any significant changes to the Code.<\/p>\n\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t","protected":false},"excerpt":{"rendered":"<p>ETHICS &amp; COMPLIANCE About Us Metg\u00fcn Group Our Mission Our Vision Quality Policy Ethics and Compliance Ethics Hotline Ethics Hotline We consider compliance with policies and rules as our fundamental principle. You can report situations that you believe are not in line with Metg\u00fcn&#8217;s Code of Business Conduct via phone, email, or through our web [&hellip;]<\/p>\n","protected":false},"author":5,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-5437","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/pages\/5437","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/users\/5"}],"replies":[{"embeddable":true,"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/comments?post=5437"}],"version-history":[{"count":0,"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/pages\/5437\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.metgun.com.tr\/en\/wp-json\/wp\/v2\/media?parent=5437"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}