Babyjem Bebek Ürünleri A.Ş. COMPANY ETHICS MANUAL
1.0 PURPOSE
The purpose of the Babyjem Company Ethics Regulation is to establish a culture of ethics, to determine the ethical rules that the personnel within the .Babyjem. Company, to help them to behave in accordance with these principles and to eliminate situations that harm the principles of justice, honesty, transparency and impartiality in the fulfillment of their duties and create distrust, and to provide guidance to ensure that they act in accordance with the ethical values of Babyjem. Company's ethical values in their relations both within the group and with third parties.
2.0 SCOPE
The rules set out in the Ethical Regulation cover all employees at all levels, including the board of directors and senior management of the companies, subsidiaries and affiliates within the Babyjem Company, as well as domestic and foreign companies.
Babyjem Company employees are required to adopt the Ethical Regulation and act within the framework of this regulation while performing their daily work/transactions. In case of any doubt regarding the content of the regulation and/or in case of witnessing a behavior or practice contrary to the regulation, the relevant managers and/or the Internal Audit unit officials should be informed directly.
3.0 RESPONSIBILITIES
3.1. Legal Responsibilities
Babyjem Company carries out all its activities and transactions at home and abroad within the framework of local laws and regulations and international law, and provides accurate and understandable information to legal regulatory institutions and organizations in a timely manner when necessary.
Babyjem Company, while fulfilling all kinds of activities and legal obligations, approaches all domestic / foreign institutions and organizations without any expectation of benefit.
3.2. Responsibilities to Society and the Environment
The Babyjem Company is committed to the protection of democracy, human rights and the environment, education and charity, and the elimination of crime and corruption.
Babyjem Company complies with the labor and labor rights laws of the country in which it is located. It supports the prevention of any illegal labor practices.
While carefully avoiding unethical behavior such as bribery, corruption or giving and accepting goods and services such as gifts in excess of the intended amount, or misconduct in office, efforts to eliminate such crimes are supported.
3.3. Responsibilities towards Employees
Babyjem Company considers the creation and maintenance of a fair working environment for employees as one of its top priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment in compliance with the relevant laws and regulations.
In human resources and business processes; race, color, ethnic origin, nationality, religion, age, gender, physical disability and similar reasons are not discriminated. Equal opportunity is provided to people under equal conditions. Remuneration and promotion criteria are based on performance and efficiency. Transparent, non-privileged and fair policies are followed in all processes (recruitment, promotion-transfer-rotation, remuneration, rewarding, training, social rights, etc.).
Babyjem Company, which adopts the principle of standing at an equal distance to all its employees, provides a safe working environment and works towards continuous improvement in this regard.
Babyjem Company complies with the highest relevant standards for the safe operation of its facilities and the health of its employees, aiming to make occupational safety an integral part of all its activities.
Employees are expected to communicate and cooperate with each other within the framework of mutual trust, respect and courtesy. Employees' private lives and personal spaces are respected.
3.4. Responsibilities towards Suppliers and Business Partners
Babyjem Company carefully protects the confidential information of the persons and organizations and business partners with whom it does business.
Treats suppliers and business partners fairly and respectfully, and shows due diligence to fulfill its obligations on time.
3.5. Responsibilities to Customers/Employer
Babyjem Company works with a customer satisfaction-oriented approach that responds to the needs and demands of its customers in the shortest time and in the most accurate way.
Babyjem Company acts honestly and fairly towards all its customers and makes every effort to fulfill its commitments to them on time and on the promised terms.
3.6. Responsibilities towards Competitors and the Industry
Babyjem Company competes with companies in the sector on legal and ethical grounds and complies with the rules of competition law.
3.7. Responsibilities of Managers
While the Code of Ethics applies to all employees, supervisory employees have additional responsibilities regarding the implementation of the Code, including
3.7.1. Establish and maintain a Babyjem Company culture and work environment that supports ethical rules,
3.7.2. Setting an example for the implementation of the code of ethics with his/her behavior, training the personnel in his/her team on the code of ethics,
3.7.3. Supporting employees in communicating questions, complaints and notifications related to ethical rules,
3.7.4. When consulted, provide guidance to the employee on what to do and take into account all notifications received,
3.7.5. Ensuring that the business processes under its responsibility are structured in a way that minimizes the risks related to ethical issues.
3.8. Health and Safety
Babyjem Company has adopted the creation of a safe and healthy working environment as a policy to prevent occupational accidents, injuries and diseases.
In all the countries in which it operates, Babyjem Company puts the health and safety of each and every one of its employees above all other considerations.
Babyjem Company encourages the development, dissemination, effective implementation and continuous improvement of the occupational safety program.
4.0 DEFINITIONS
This is in the regulation;
Babyjem Company : BABYJEM BEBEK PRODUCTS SAN.TİC.LTD.ŞTİ founded by Cem Vatansever
Regulation: Babyjem COMPANY Ethics Regulation
Board of Directors: Babyjem Company Board of Directors
Chairman of the Board: Refers to the Chairman of the Board of Directors of Babyjem Company.
5.0 APPLICATION
5.1. GENERAL PRINCIPLES AND RULES
The companies within the Babyjem Company continue their activities in different countries of the world where different ways of doing business are adopted, and expand their field of activity and influence day by day. As a result of this expansion, the risk of being exposed to unethical behavior both internally and externally increases. In order to manage the risk of exposure to unethical behavior, Babyjem Company has determined its own ethical values and shared these values with its employees. Babyjem..... In addition to its own employees, the Company expects third parties such as customers, vendors, suppliers, representatives, affiliates with whom it has business relations to comply with the Code of Ethics, and takes into account its past experiences in compliance with these rules in its future business relations.
Compliance with the principles and rules set out in the Ethical Regulation is a continuous process and requires employees to make informed decisions based on a certain logic and that these decisions are in line with the standards and culture of Babyjem Company. All employees of Babyjem Company must fulfill their responsibilities in these areas. Compliance with the Code of Ethics is closely monitored by Babyjem Company and is taken into consideration in the performance evaluation process and career development of employees. Violation of the matters specified in the Code of Ethics is penalized in accordance with the Babyjem Company Disciplinary Procedures Procedure (Disciplinary Procedures Procedure number will be written here). Violation of the Code of Ethics by third parties with whom the business relationship is established results in termination of the business relationship.
5.1.1. Honesty
Babyjem Company employees adhere to the principle of truth and honesty in their relations with customers, suppliers, shareholders, competitors and public institutions.
5.1.2. Reliability
Babyjem Company aims to be a symbol of reliability and respectability towards its partners, employees, suppliers, business partners, competitors, environment, society and humanity. By fulfilling its responsibilities on time and completely, it considers the principle of trust as one of the basic elements of commercial success.
Babyjem Company personnel act in a way to ensure the trust of the Babyjem Company management and show with their behavior that they are worthy of the reputation and trust required by the duty and refrain from engaging in behaviors that undermine the sense of trust in Babyjem Company activities, create suspicion and harm the principle of justice.
5.1.3. Business Ethics
Babyjem Company employees act openly, respectfully, honestly and with a sense of responsibility when sharing their thoughts and opinions.
The spirit of teamwork encouraged throughout the Babyjem Company is based on the sharing of all kinds of work results and information generated in the organizational structure, in compliance with the principle of enough information when necessary.
It is against ethical values to make baseless and unfounded statements and/or gossip about individuals or organizations and to malign colleagues.
In the conduct of Babyjem Company business, employees must respect the rights and cultural differences of individuals.
All forms of harassment and mobbing are strictly prohibited in companies within the Babyjem Company.
Political, social and religious views cannot be discussed in the work environment.
Employees must refrain from using Babyjem Company's name, corporate identity, reputation and power for personal benefit.
All personnel fulfill their responsibilities for the protection and development of the reputable image of Babyjem Company. Within this framework, employees take care to ensure that their personal conduct and behavior are within the framework of the provisions of the legislation and general ethical rules. Employees, Babyjem. Company in favor of themselves and others.
5.1.4. Impartiality, Fairness and Transparency
Babyjem Company does not consider differences such as nationality, religion, language, race, gender, financial and social status among its employees, customers and suppliers, and avoids prejudiced behavior. The Group observes the principle of justice both among its own employees and in its relations with third parties with whom it has business relations. The Group avoids personal or institution-specific and short-term practices and applies standard practices for all related parties.
5.2. POLICIES SUPPORTING THE CODE OF ETHICS
5.2.1. CONFLICT OF INTEREST POLICY
It is essential for Babyjem Company employees to avoid situations that may create a conflict of interest. It is one of the most important responsibilities of employees not to use the resources, name, identity and power of Babyjem Company for personal benefit and to avoid situations that will negatively affect the name and image of the organization.
The following code of practice sets out the conflict of interest situations that Babyjem Company employees may encounter in the performance of their duties or in their private lives due to their business relationships and the principles to be applied in these situations, and these principles must be fully complied with.
Code of Practice;
5.2.1.1 Engaging in Activities that may Create Conflicts of Interest
Employees shall not enter into any business relationship with family members, friends or other third parties with whom they have a relationship that provides reciprocal or non-reciprocal benefits under any circumstances. For example, an employee with purchasing authority should avoid doing business with a supplier owned and/or employed by a family member. Exceptional cases (when there is no other alternative) are subject to the knowledge and approval of the Board of Directors. In the same direction, Babyjem Company employees should be careful against conflicts of interest that may arise due to the employment of close family members in Babyjem Company competitors.
Managers who are in a position to make hiring decisions cannot hire their spouses, close relatives (blood and in-law relatives up to and including 3rd degree) and their relatives.
It is essential that the employees of Babyjem Company do not directly or indirectly engage in activities that require them to be considered as "merchants" or "tradesmen", and that they do not work for another person and/or organization for a fee or similar benefit, under any name whatsoever, during or outside working hours.
Babyjem Company employees may not serve as a board member or auditor in companies other than Group Companies without the approval of the Board of Directors, and may not work in competitors or companies with which Babyjem Company has business relations.
On the other hand, they may take part in non-profit organizations, social responsibility projects, sports federations and universities with the approval of the Board of Directors, provided that they do not interfere with their duties.
Babyjem Company resources and facilities cannot be used to support political activities, donations cannot be made to political parties and political campaigns cannot be supported.
Babyjem Company employees may be active in any political party with their individual decisions. However, managers cannot ask their employees to do a political job or become a member of a party. It is possible for employees to take part in any political party under the following conditions and with the approval of the Board of Directors;
-Employees' involvement in any political activity should not create a conflict of interest with their duties in the company and the practices and approaches of other group companies.
-Workers may not engage in any political activity during working hours and may not take up the time of their colleagues in connection with such activities.
-Employees may not use the company name, position, title and resources of the company during their political activities.
Employees involved in political activities are expected to make it clear that they do not represent Babyjem Company.
5.2.1.2 Abuse of Duty
Employees cannot use their powers for their own and/or their relatives' benefit. In addition, it is unacceptable to harm Babyjem Company by using authority other than the care expected from him/her.
Employees cannot obtain personal gain directly or indirectly through a family member or relative from all business, transactions and contracts to which Babyjem Company is a party, such as activities, purchases and sales.
They may not use the means (credit card, vehicle, etc.) entrusted to them due to their duties for their private purposes.
Employees may not engage in acts and behaviors contrary to morality, law and Babyjem Company discipline.
5.2.1.3. Bribery and Corruption
No Babyjem Company employee may take part in giving/receiving bribes or similar criminal activities. Such criminal activities for the purpose of gaining benefits are strictly prohibited.
In the legislation of many countries; corruption, bribery or attempts for this purpose are criminal activities and are subject to sanctions, including imprisonment. For this reason, Babyjem Company carefully monitors those who act on its behalf in order to prevent bribery and corruption behaviors and attempts in accordance with the sensitivity it shows to the issue.
The Babyjem Company also takes a similar approach to the so-called facilitating payments that come to the fore, especially abroad, under any name, and it is strictly forbidden to make such payments.
5.2.1.4. Unfair Competition
Babyjem Company complies with the laws of the country in which it operates regarding competition and unfair competition.
Babyjem Company recognizes competition as a competition in accordance with the legislation that enables free economic decisions to be made among all companies in the sectors in which it operates. Group companies avoid behaviors that constitute unfair competition within the framework of the principles of striving for the development of the sector in general, observing common interests, as well as corporate interests in activities carried out in a free market economy. Babyjem Company employees do not express positive or negative opinions about competing organizations and their services during their duties.
Although it varies on a country-by-country basis, legislative provisions may stipulate serious sanctions for unfair competition. Babyjem Company employees are expected to conduct their relations with competitors in line with the principle of honesty and not to take part in practices that create unfair competition. It is extremely important that Babyjem Company employees are aware of the legal legislation on unfair competition, and that suppliers and customers do not carry out unfair competition-generating transactions that may adversely affect Babyjem Company's activities.
Suppliers, customers and industry partners are important to the success of Babyjem. It is important for Babyjem to be fair in its relations with these business partners and to treat them with integrity and respect. Babyjem Company selects all of these business partners based on criteria such as performance, price, technical and financial competence and quality.
5.2.1.5. Money Laundering
Babyjem Company strictly prohibits the use of any of its activities for illegal activities such as money laundering and obliges all its employees to inform the senior management in case of any suspicious situation.
5.2.1.6. Cheating
Cheating is the intentional improper use or appropriation of an employee's resources and assets to gain an unfair advantage.
Babyjem Company is committed to creating an honest, open and good faith working atmosphere. In this direction, in the event that any "Cheating" situation is determined, it shows a firm determination to carry out the investigation/investigation process to identify those responsible.
Situations referred to as "cheating" include, but are not limited to, the following examples;
- Embezzlement of money, material or other assets,
- Irregularities in purchase and sale processes,
- Misuse of company money,
- Inappropriate reporting of financial transactions for self-interest,
- Deliberate misrepresentation of financial information, performance results,
- Deliberately making inappropriate expenditures appear to be in line with company procedures,
- Deliberate alteration of company documents to mislead users.
Any suspected or suspected fraud will be reported to the Human Resources Unit and the matter will be investigated in accordance with the provisions of the current Disciplinary Procedure (the Disciplinary Procedure number will be written here).
The results reached after the investigation by the Human Resources Department will not be shared with anyone other than those who need to know them. This is important in order to prevent damage to the reputation of those who are suspected of wrongdoing but are found not to be at fault and to protect Babyjem Company from possible legal processes.
5.2.2. GIFT ACCEPTANCE AND GIVING POLICY
It is essential that Babyjem Company employees do not accept gifts or benefits that are implicitly/explicitly linked to a quid pro quo or that may affect their impartiality, decisions and behaviors, and do not attempt to provide gifts and benefits to third parties and organizations that may have such effects.
The application principles defined below regulate the gift exchanges that may arise with third parties and organizations with which Babyjem Company employees have a business relationship.
Code of Practice;
5.2.2.1. It is forbidden for Babyjem Company employees to receive all kinds of benefits and gifts, with or without economic value, that affect or are likely to affect their impartiality, performance and decision-making while performing their duties.
5.2.2.2. Employees of the Babyjem Company;
- Aligned with the organization's business objectives,
- Compliant with applicable legislation,
- Provided that the public disclosure of the gift will not put Babyjem Company in a difficult situation, it may receive and/or give the gifts outlined in Article 5.2.2.3.
5.2.2.3. (5.2.2.2.2.) provided that it complies with the conditions specified in Article (5.2.2.2.);
- Babyjem Company employees may give and receive refreshments and meals at standards acceptable in the business world.
- In seminars and similar organizations attended on behalf of Babyjem Company, gifts such as prizes, mattresses, etc. with symbolic value may be received as a memory of the day.
5.2.2.4. Receiving, giving or offering kickbacks is not acceptable under any circumstances.
5.2.2.5. Babyjem Company employees are prohibited from accepting money from suppliers, competitors or customers for free or as a loan, reimbursing travel expenses, event expenses and similar payments.
5.2.2.6. ..... The gifts and promotional materials to be given to other third parties with whom the Company has a business relationship are approved by the Senior Management of Babyjem Company. There is no need to obtain permission for the distribution of approved gifts and promotional materials.
5.2.2.7. In exceptional cases, especially abroad, where local cultural values require reciprocal gift giving, these gifts may only be accepted on behalf of Babyjem Company and with the approval of Babyjem Company Senior Management. In any case, gift exchange must be done in accordance with the local culture.
5.2.3. CONFIDENTIAL INFORMATION PROTECTION POLICY
5.2.3.1. Trade Secret
Information and documents, trade secrets, financial and other information not disclosed to the public, confidential information regarding the personal rights of employees and confidential information in agreements made with third parties are evaluated within the framework of confidentiality and protection of trade secrets.
In the event that employees leave the company for any reason whatsoever, they may not use any and all documents, papers and information they possess due to their duties and positions in order to gain advantage for themselves and/or competitors against the company in the future.
It is forbidden to obtain benefits in any way by leaking any confidential information and/or documents belonging to Babyjem Company.
Babyjem Company employees are also obliged to pay attention to the confidentiality and protection of private information of its customers, suppliers, business partners and other persons and organizations working together.
All official disclosures are announced to shareholders and the public through the units designated by the company in a complete, simultaneous and understandable manner in line with the principle of equality.
The persons authorized to communicate with analysts, capital market professionals and media representatives on behalf of Babyjem Company, to make evaluations and express opinions about the Company, and to make press releases to the written and visual media and similar data distribution channels are determined by the Board of Directors.
5.2.3.2. Privacy and Information Security
Babyjem Company takes care to protect the personal information of its employees and all stakeholders.
The employee is responsible for maintaining the security of the address allocated to employees for e-mail use. Under no circumstances shall the employee allow anyone else to use his/her e-mail.
Employees are responsible for the individual use of the user logins allocated to them for the IT software used by the company. The employee does not allow anyone other than himself/herself to access any system entered with an individual user password using the same user name and password, and is responsible for the security of the user name and password allocated to him/her.
Company-specific information, whether on the public network or on personal computers allocated by the employer for business purposes, cannot be shared with outside the company.
The employee is responsible for the security of personal computers, except for those allocated for common use.
A Babyjem Company employee may not search another employee's workspace and/or computer.
Wages/salaries, additional income and similar personnel information that reflects company policy and is personal to individuals are confidential and may not be disclosed to anyone other than authorized persons. Staff are prohibited from disclosing it to others or pressuring other employees to disclose it.
PERSONAL DATA PROTECTION
In order to ensure that your personal data is collected, stored and shared in accordance with the law and to protect your privacy, our company takes the highest level of security measures possible and acts in accordance with the obligation of disclosure within the framework of the principle of transparency regarding the ways of obtaining personal data, the purposes of processing, the persons shared, the legal reasons for sharing and your rights of citizens in accordance with Article 10 of the "Personal Data Protection Law" numbered 6698.
BABYJEM complies with the obligations of providing products and services, organizing records and documents, storing, reporting and informing information stipulated by domestic and international legal legislation and determined by official institutions.
Personal data is processed only within the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 for the analysis of customer demands and market expectations.
5.2.4. POLICY ON THE PROTECTION AND USE OF COMPANY ASSETS
It is among the responsibilities of employees to protect, prevent loss, damage, misuse or waste of Babyjem Company assets and not to transfer them to unauthorized persons.
It is a general rule to refrain from using the assets and resources of the Babyjem Company for personal and third-party benefit. The use of the internet, telephone and e-mail for personal purposes is appropriate provided that it does not violate the law, is not excessive and does not create additional costs. Individuals are personally responsible for any legal proceedings that may arise in this case.
5.3. IMPLEMENTING THE PRINCIPLES OF ETHICAL BEHAVIOR AND ESTABLISHING AN ETHICAL CULTURE
5.3.1. Compliance with the Principles of Ethical Behavior
Babyjem Company employees are obliged to comply with the Ethics Regulation while carrying out their duties. These rules form part of the legislation provisions regulating the employment of Babyjem Company employees. The rules specified in the Code of Ethics are applied in all Babyjem Company units.
Babyjem Company managers also evaluate the status and performance of the personnel in terms of compliance with ethical rules.
5.3.2. Informing the Staff
Personnel at all levels working within the Babyjem Company are informed about the code of ethics and their responsibilities in relation to this code as part of the conditions of employment.
5.3.3. Embedding Ethical Culture and Education
The Senior Management of Babyjem Company carries out all kinds of studies it deems necessary for the establishment and development of ethical culture, has them carried out, prepares, coordinates and conducts training programs for its employees when needed, or may cooperate with expert organizations on these issues.
5.3.4. Investigation and Research Authorization
The Human Resources Unit is authorized to carry out the necessary examination and research on behaviors and practices contrary to ethical rules, either ex officio or upon applications to be made. While exercising this authority, information and documents are requested from the relevant units when necessary as a basis for the examination and research to be carried out on behaviors and practices contrary to ethical principles.
The review and research is conducted within the framework of whether ethical rules have been violated.
5.4. PROCEDURES AND PRINCIPLES FOR APPLICATION AND EX OFFICIO REVIEW
5.4.1. Application Procedure
All . Babyjem Company employees have the right to claim behavior contrary to ethical rules and submit information and documents regarding their claims to the Human Resources Unit. The identity of the employees who report the situation is kept strictly confidential.
All employees, customers or suppliers who wish to convey information, make suggestions or consult the Human Resources Unit etik@babyjem.com.tr can send an e-mail to.
5.4.2. Acceptance and Processing of Applications
The recorded application is taken under review for evaluation by the Human Resources Disciplinary Board Review Unit.
The Board examines the application in terms of task, subject matter and admissibility, prepares a preliminary report and submits it to the Chairman of the Board of Directors.
If necessary, it is decided to request the necessary information, opinions and documents from the relevant units by deepening the examination. If the application is found acceptable, the defense of the relevant employee is taken. The defense period is 7 days starting from the day following the date of notification of the request letter. In case the last day of the period coincides with an official holiday, the working day following the holiday shall be considered as the last day of the period.
The units and/or companies within the Babyjem Company from which information is requested are obliged to provide information and documents within the specified period.
The investigation shall be completed within a period of two months at the latest, and the Disciplinary Board shall be requested to be called to duty, if necessary, with the report prepared.
Applications that are later found to contain untrue statements shall be removed from the process on the date when this situation becomes known.
5.4.3. Action to be taken on the Report
In the event that a Babyjem Company employee is found to be in violation of the Ethical Regulation, a report on this situation shall be submitted to the Chairman of the Board of Directors by the Disciplinary Board.
Those who violate the Ethics Regulation will be subject to the provisions of the Disciplinary Regulation. Disciplinary sanctions shall also be applied, when necessary, to those who approve, direct or have knowledge of improper behaviors and acts that lead to breaking the rules, but do not make the necessary notification appropriately.
The result of the examination that no behavior contrary to the ethical principle has been detected is also submitted to the Chairman of the Board of Directors.
5.5. FINAL PROVISIONS
5.5.1. Enforcement
The Code of Ethics shall enter into force on the date it is approved and published by the Chairman of the Board of Directors.
5.5.2. Execution
The provisions of this directive shall be executed by the Chairman of the Board of Directors.
