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Corporate Ethics

Article 1) Tepe Betopan Business Ethics Tepe Betopan Handbook of Business Ethics (TBEK) applies to all employees of Tepe Betopan Yapı Malzemeleri San ve Tic. A.Ş. (TEPE BETOPAN) regardless of their duty, seniority level and term of employment. With TBEK, it is aimed to define the ethical rules that all employees must comply with and inform the employees. All employees are required to act in accordance with the TBEK while communicating or maintaining their existing relations with internal and external stakeholders. In case of non-compliance with the rules set out in TBEK, sanctions are imposed by the executives.

Article 2) Consultation If there is a doubt in the implementation of TBEK and/or a non-compliance is identified, the employee must first contact his or her Department Manager and report the situation. In case of a situation that is contrary to the TBEK is identified or suspicion of a situation that is not mentioned in the TBEK but is contrary to the national and international laws and/or publicly accepted ethical rules and if it is considered that TEPE BETOPAN and Bilkent Holding's reputation is compromised, the matter is immediately reported to the Department Manager. When there is an issue that is considered and/or suspected to be against the business ethics and it is not possible to contact the Department Manager, the matter is reported immediately to the HR Department and/or notified via electronic mail to etik@betopan.com.tr. The e-mails sent to this e-mail address are examined by the company authorities and the information about the result of discussions and evaluations made with the authorized persons/organizations is also notified to the employee who reports the issue.

Article 3) Integrity and Reliability The constitution of the Republic of Turkey as well as all laws, national and international rules of law and all ethical values accepted by the society are complied with in the company's operations. The responsibility towards the employees, suppliers, competitors, environment, society and humanity is maintained at the highest level and operations are performed within the principles of integrity and reliability.

Article 4) Conflict of Interest The situations where personal interests conflict with company interests are not allowed. Employees may not gain benefit by using company's resources, business potentials and brand power for their families, relatives and business contacts. If any first degree relative is employed in any other company, institution and organization with which the company has a business relationship, this is reported to the Department Managers. Employees may not share any information, rumors and developments about TEPE BETOPAN and Bilkent Holding Companies with their families, relatives or their close contacts and allow any ill-gotten gain intentionally or unintentionally. They do not engage in relationships with existing and potential customers, suppliers and competitors outside the company.

Article 5) Giving and Accepting Gifts Gifts from customers, suppliers, competitors or third parties may not be accepted without the knowledge of senior management, and third parties may not be offered gifts in a way to affect their impartiality and decision-making processes. Gifts of cash or cash equivalent are rejected regardless of their amounts. Employees may not have any debt-credit relationship with suppliers, customers, competitors and third parties in any way for any reason whatsoever. Gifts and incentives other than those materials which are approved by the senior management as part of the Sales-Marketing activities and approved for distribution to suppliers, customers, institutions and organizations are strictly not used.

Article 6) Confidentiality Information that is owned by TEPE BETOPAN and Bilkent Holding Companies and cannot be disclosed for the purposes of competition, including but not limited to financial information, intellectual and industrial rights, product and process designs, innovations, discoveries and patents, pricing works, marketing strategies, internal and external correspondence, legal processes, customer and supplier lists and details, meeting talks and minutes, information on personnel rights and confidentiality agreements signed with third parties, directives, regulations, instructions and any similar information, is confidential and proprietary information. Confidential and proprietary information is only used for valid business purposes and maximum care is taken to ensure that measures are taken in order to prevent their use against the company in the future. The obligation of employees to protect confidential and proprietary information survives after termination of their employment with TEPE BETOPAN and/or Bilkent Holding. No employee other than the Members of the Board of Directors and/or the General Manager and the persons authorized by them may make an oral or written statement on behalf of TEPE BETOPAN.

Article 7) Competitors and Competition Information about the competitors in the sector is collected to the extent permitted by law and ethical rules. Accordingly, while collecting information about competitors, public information and documents and news reported in the printed and visual media are used. The information and documents that are offered about the competitors contrary to the applicable laws and general ethical rules are not accepted, shared with third parties and used for the company's interests. The company does not participate in potential or ongoing tenders by acting contrary to the general competition rules.

Article 8) Bribery and Corruption No bribes and/or commissions may be granted and even offered for the private or public sector. No interest may be gained and no basis is created for future negative developments against the company by offering bribes and/or commissions and committing any illegal or improper act.

Article 9) Facilitation Payments No facilitation payments are made regardless of their amounts in order to facilitate the company's business processes. In case the representatives of the institutions or organizations with which the company has a relationship expect such payments, the matter is immediately reported to the Department Managers.

Article 10) Use of Resources The resources allocated by the Company may not be used for personal purposes. Working hours are considered as the most valuable resource and treated in the most efficient way in line with the interests of the company. Company assets may not be used incorrectly in an intentional or unintentional way and may not be wasted or transferred or made available to third parties. Excessive use of the communication means, such as telephone, internet and e-mail facilities which are allocated by the company for use during the activities are avoided.

Article 11) Financial Reporting It is ensured that financial records and data comply with national and international regulations. All books and records are submitted and audited by the legal authorities and Bilkent Holding's Internal Audit Bodies and Independent Audit Firms as required.

Article 12) Principles of Employment Employees are the most valuable assets of TEPE BETOPAN and the Bilkent Holding family and thus it is aimed to provide them with opportunities beyond the standards required by the laws. It is one of TEPE BETOPAN's priorities to ensure that employees always work in a healthy and reliable environment. The company operates with the awareness that providing healthier and safer workplace conditions is not only a responsibility to employees, but also a responsibility to the whole community, customers and environment. Employees of TEPE BETOPAN are not allowed to act with any behavior, aggressive attitude, threatening speech and forms of act to disrupt working environment efficiency and confidence, to commit any abuse and disturbance, to make any promotion for commercial, political and religious purposes, and to tamper with the official documents they prepare while performing their duties. Employees are obliged to obey the time and other restrictions specified by the relevant authority in the preparation of official documents.

Article 13) Fair Work Environment and Equal Treatment Every employee is a source of wealth for the company and as such, employees are valued as required. All employees are expected and supported to act with respect and understanding towards each other, regardless of their duty, seniority level and term of employment. The company operates with the awareness that peace at workplace affects the sense of belonging and professional success. Employees are treated equally without any distinction and it is observed that the labor standards determined by the company's senior management are applied equally for each employee. In professional relations, it is not allowed to exhaust the employees intentionally or unintentionally, expose them to personal abuse and humiliations or use mobbing on the employees.

Article 14) Brand Protection The company acts in a sensitive way to protect the prestige of our registered trademarks which have high commercial reputation in the national and international markets. Any conduct that may undermine the brand value is avoided with the awareness that protection and promotion of brand value is important not only for the company, but also for the society, customers and country. National and international standards are observed in all operations in order to protect and promote the brand value.

Article 15) Social Responsibility All employees of TEPE BETOPAN take care to protect the environment and natural life and avoid damaging activities. In the products, the consumer rights and public health issues are treated responsibly and the applicable rules are complied with. In order to fulfill the social responsibilities of company, sustainable projects are developed in a way to contribute to the development of the society. Immediate action is taken as soon as the damage is identified without waiting for legal and social warnings to compensate the damage caused to the society or the environment unconsciously and the society is informed accordingly.

Article 16) We do not employ child labor in exchange for basic labor needs. There is no discrimination in language, religion, race or social status among our employees. There is no forced labor in our organization. The union rights and freedoms of our employees are respected.


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