Ethics is a set of values, norms, rules that form the basis of individual and social relations that people establish, and a set of measures that investigate morally such as right-wrong or good-bad.

The ethical principles of Şahince Otomotiv Sanayi ve Ticaret A.Ş. are a set of rules that all of our employees, especially the members of our Board of Directors and managers of our company, must comply with and lead other employees to act in accordance with these principles for the personal success of both our company and our employees.

Our Ethical Principles are complementary to Şahince Otomotiv Sanayi ve Ticaret A.Ş.’s Internal Regulations.

1. RESPONSIBILITIES

1. The Company’s Responsibilities towards its Employees

• Şahince Otomotiv Sanayi ve Ticaret A.Ş. fully fulfills its legal obligations towards all its employees, and in cases where the laws are insufficient for the applications, people who are specialized in the subject are consulted.
• In recruitment and promotions, it takes into account the qualifications suitable for the task and creates equality of opportunity among employees.
• It does not interfere with the private information of its employees and the private lives of its employees, and keeps all kinds of information about its employees confidential.
• Organizes trainings on issues that will ensure the business and personal development of employees.
• It does not discriminate on the basis of gender, age, ethnic origin and religious belief in its practices towards employees.
• Creates healthy and safe working conditions at the level required by laws and conditions and tries to improve them within the limits of possibilities.
• It reserves and does not share personal information (such as health information, shopping details, economic data, etc.) about employees that can be obtained through various channels.
• Employees may not be retaliated against for reporting in good faith a suspected violation or actual violation of the ethics policy. Retaliation is a very serious violation of the Code of Ethics and will be reported immediately.

2. Responsibilities of Employees towards the Company

• Şahince Otomotiv Sanayi ve Ticaret A.Ş. employees strictly reject any material and moral offers that may come from third parties in order to direct these activities while carrying out activities within their areas of responsibility.
• Employees show the utmost care and attention while fulfilling the assigned task and strive to ensure that the work performed is of better quality, faster and more economical.
• Employees shall refrain from any behavior that may damage the image and reputation of the company and shall not deviate from the style of dress and behavior predetermined or generally accepted by the company management during working hours.
• Şahince employees do not remain insensitive and unresponsive to situations contrary to the interests of the company and inform the relevant units.
• Employees avoid wastage by using all fixtures, tools and equipment of the company for their intended purpose. They do not use the facilities provided by the company for their private affairs.
• Employees shall not leak confidential and private information learned as a requirement of their position or work outside the company, and shall not give interviews, statements or declarations to visual or written media organizations on company-related issues without the approval of the company management.
• Employees show sensitivity to issues that are accepted by all parties as contrary to general morality and share or report any issues that have a negative impact on social peace (sexual harassment, slander, mobbing, sexual discrimination, etc.) with the company authorities (department managers and senior management).
• It expects all its employees to respect their privacy, personal rights and personal dignity.

3. Responsibilities of the Company towards the Companies

• Şahince Otomotiv Sanayi ve Ticaret A.Ş. acts in accordance with legal rules in all its activities.
• It does not provide any unfair gain from individuals and organizations for any purpose whatsoever.
• The decision to purchase a product or service is based on established and shared criteria.
• Checks that the continuous services received from other organizations are provided in accordance with the law and makes the necessary follow-up.
• It does not share the private information of the companies that serve it with third parties without their permission.
• The company plans, implements and controls processes appropriate to the company and the product to prevent the use of counterfeit or suspected counterfeit parts and their incorporation into the product(s) delivered to the customer.
• Avoids the knowingly unauthorized use of patents, copyrights, trade secrets, trademarks, brands, computer programs and other intellectual and industrial property rights of other companies.
• Shahince protects intellectual property rights and prevents damage to intellectual property rights through the legitimate use of intellectual property rights and the avoidance of misuse.
• Does not compromise the principles of fairness, integrity and honesty in competition. Competes in accordance with antitrust laws.
• In all duties and activities throughout the company, company interests are observed and conflicts of interest are avoided. Our company is against bribery and all forms of corruption and shows zero tolerance. It is extremely sensitive in the fight against bribery and corruption and does not allow personal interests to affect its ability to pursue company interests, which is our top priority. Personal or close relatives/friends are not benefited by using their positions, responsibilities within the Company or the identity of the Company. Compliance with anti-corruption laws is ensured. The highest standards of integrity are observed in all business transactions. No gifts or benefits, business dinners or entertainment are requested from our customers and suppliers.

4. Company’s Responsibilities to Society

• Şahince Otomotiv Sanayi ve Ticaret A.Ş. strives to reach the service standards that its customers expect from it.
• It aims to fulfill its tax and other legal obligations fully and on time, and to be an example to the society.
• Does not use condescending, sarcastic and offensive expressions about other institutions and organizations, products and persons.
• In its activities, it takes care not to damage the environment, historical texture, and to act in accordance with customs and traditions and complies with all legal regulations in this regard.
• By advocating business ethics in its own sector, it strives for the establishment, dissemination and adoption of these principles.
• The Company monitors the financial statements or operating results accurately and objectively in accordance with laws and regulations and internal rules,
• The Company applies the necessary controls in the transfer of any goods, services or technology subject to foreign trade as a requirement of the internal regulations established by countries with national security concerns and also as a requirement of international responsibilities and cooperation.
• The Company recognizes that trade and financial penalties imposed by one or more countries against a targeted state, group or individual are economic sanctions and operates accordingly.

5. Responsibilities of Employees towards Employees

• Employees do not share the private information they obtain about company employees with anyone other than those required by their job. They do not disclose company information.
• Employees are aware of illegitimate actions and behaviors contrary to applicable laws and socially accepted ethical values and principles, and make a conscious announcement to the company or persons who may be affected by such actions and behaviors or who can prevent such actions and behaviors.

1. ETHICAL PRINCIPLES MANAGEMENT AND COMMUNICATION

Reports to the ethics team (Human Resources Officer, Company Lawyer, Employee Representative, Management) that evaluates situations that violate our ethical principles etik@sahince.com.tr and phone notifications to the Human Resources Officer (0 533 296 13 29), the relevant situation is evaluated and actions are taken.

The complainant or (Employee Representative) is also consulted during action planning in the improvement and solution process.

Complaints to the ethics committee are divided into human rights complaints, unethical business practices (mobbing, etc.) and environmental complaints.

The issue received by phone or e-mail is quickly transferred to the Ethics Committee, evaluated and the Ethics Committee notifies the complainant of its opinion within a maximum of seven days from the date of application.

The identity of complainants is kept confidential during this process.

Complaints can also be submitted anonymously to the addresses indicated.

The ethics committee meeting schedule should be determined 48 hours in advance.

The effectiveness of the grievance procedure is evaluated by the Ethics Committee members at least once every 12 months and reported to the management.

ŞAHİNCE TOMOTİV A.Ş.
On behalf of Senior Management,
Ozgur Sahin
General Manager