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This Code describes and explains Gülermak’s business and management ethics.

All full or part-time employees and any other person who works for Gülermak should take ethical business conduct into account while they are fulfilling the requirements of their jobs and responsibilities. This code is designed:  

• To promote Executive Board, directors and managers to give importance to the business ethics;
• To inform the staff on what kind of behaviour is not suitable in work;
• To report unethical behaviours;
• To promote the values and principles it embodies and to deter any wrongdoing.

It is obvious that any rules and prohibitions would not be sufficient to prevent a delinquency.

The Code of Business Ethics is crucial in ensuring that all employees are aware of the standards we have set for Gülermak. In this regard, employees' knowledge will be refreshed and updated periodically in accordance with Gülermak's Code of Business Ethics and employees are required to certify that they comply with this Code.

They are expected to fulfil their job requirements and responsibilities while professionally evaluating and judging the faults in the management processes in an objective manner.

All employees should behave professional and act responsively while conducting the works attributed to them.

Any kind of misconduct, misuse, waste, over- or mis-consumption of any kind of resources has to be prevented.

Conflict of Interest

All employees should pay attention not to cause any possible conflict between their personal and Gülermak’s interests and should notify any potential conflict immediately to Ethic Committee through ethic@gulermak.com email with identity or anonymously. Annually, all employees will complete a questionnaire regarding potential conflicts of interest.

Conflicts of interest may occur in the following situations:

• In cases when an employee’s personal interest is conflicting or likely to conflict with another employee’s personal interest, or with the interest of Gülermak;
• In cases when there is a happening, or likeliness of the happening of an incident or an event which hinders an employee from fulfilling their duties objectively and effectively;
• In case of an employee’s using his position in order to take advantage in relation to his or to his relatives’ interests.
• Occurrence of situations similar to the ones listed above, and even the probability of occurrence of such situations should be informed immediately to head of business unit and/or Ethic Committee of Gülermak.

Work Opportunities

All employees:

• may not use, and may not take advantage of Gülermak’s property, information or position in favour of their own selves;
• may not compete with Gülermak (directly or indirectly).

Confidentiality

All employees who have access to confidential information provided by Gülermak, other employees or clients are legally responsible for maintaining the confidentiality of given information. 

Confidential information is any data or information that is not public or that may have negative impact on Gülermak and its client’s interests, or that can be used by competitors.

Anti-Mobbing & Anti-Discrimination

Gülermak does not tolerate any form of discrimination, harassment, mobbing and bullying behaviours under any circumstances.

Any verbal or physical acts which is aimed at or results in the humiliation or ridicule of the employee, or the isolation or elimination of the employee from the group of staff is forbidden, no matter if the act is short, persistent and long-term. Any forms of harassment or discrimination related to an individual’s gender, age, handicap or disability, race, physical appearance, religion, nationality, political views, ethnical background, sexual orientation or other protected category are a violation of the law and this policy.

All employees are treated with dignity and respect at workplace. Offensive, insulting, threatening, intimidating behaviours, any sexual advances, humiliation, stalking, isolation and non-cooperation, persistent and unjustified criticism, behaviour(s) which an individual knows would cause fear or anxiety to another, hindering the performance at work, harassment by phone, are examples of such unwanted conduct, therefore, must be immediately reported to Gülermak.

The Employees who believe that they or another employee were the object of mobbing, harassment or discrimination or which witnessed mobbing, harassment or discrimination occurrences are entitled to report such occurrences to the Senior Management or Anti-Mobbing Committee by sending e-mail to antimobbing@gulermak.com with employee's identity or anonymously. The identity of the employee reporting the occurrence, even if known, remains confidential. Gülermak Anti-Mobbing Committee shall act immediately regarding the investigation, disposition or resolution of the issue.

Fair Treatment

All employees should act fairly and equally to Gülermak’s clients, sub-contractors and suppliers. Nobody can take advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

Protection and Proper Use of Company Assets

All employees are responsible for protection, proper and efficient use of company assets.

Theft, negligence and waste have direct negative impact on Gülermak’s profitability. Company assets should be used only for legitimate business purposes.

Accuracy of Recording and Reporting

All employees are obliged to use applicable internal systems for maintenance and use of records, accounts as well as for internal audits and statements.

Manipulation of Gülermak’s records in any way is prohibited.

All reports, documents and correspondences, should be stored and processed in complete, correct, accurate, and understandable way.

Compliance with Law Rules and Regulations

Every person who works for Gülermak have to fulfil requirements of their job according to all applicable laws, and mandatory and regulatory rules and regulations. Especially, they have to avoid any involvement in any kind of corruption and also in internet-based crimes.

Being Gülermak operating in multiple countries and markets, it is therefore subject to the general principles, adopted in many competition laws of free and fair trade.

It is the policy of Gülermak and the obligation of every person who works for Gülermak to strictly comply with the applicable competition laws.

Gülermak will make arrangements to promulgate this code and make available adequate learning opportunities for its employees to understand and therefore comply with any competition law obligations.

Relations with Public Administrations and Institutions

Gülermak promotes legitimate and correct relations with the Public Administration and Public Institutions, within the context of maximum transparency and while refusing any form of promise or the offer of payment or goods to promote or favour any interest or advantage.

No person who works for Gülermak is allowed to offer money or gifts to all employees of the Public Administration and Public Institutions, or to their family members, unless gifts or advantages are of a modest value.

When any business negotiations, requests or relations are in progress with the Public Administration and Public Institutions, people who work for Gülermak must not try to inappropriately influence the decisions by the counterparty, including those of officers who negotiate or make decisions on behalf of the Public Administration and Public Institutions.

Should any person receive requests or offers of benefits from public officers, they must immediately suspend relations and report the fact according to the provisions of this code.

In case of entering contracts with public administrations, may apply special, complex laws, rules and regulations.

Nonfulfillment of any regulations may constitute a criminal offense. Therefore, in order to fulfil all regulations, it is advised to request support from appropriate people within the company or, if necessary, from appropriate legal institutes or consultants.

Political Involvement

Gülermak is completely outside of any political party and organisation.

Along these lines, Gülermak may financially back said organisations or associations in a transparent manner and solely in compliance with the applicable legislations.

Reporting of Inappropriate and not Ethics Behaviour

All employees should encourage all other employees to work according to Code of Business Ethics and in case of violations or any doubts should report immediately to their supervisors/managers and directors, or to a higher level of organisation without limit, if feel uncomfortable to share with direct supervisors.

All supervisors, managers and directors are responsible for reporting any violations of ethics rules to the Head of Business Unit, Ethic Committee or Executive Board. All violations will be examined by Ethic Committee and then necessary sanctions shall be applied by Executive Board. Gülermak, regardless of the intention, will not allow any retaliation against any violation, reporting of inappropriate and unethical behaviours.

Breaches and violations of this code may also be directly reported (to whistleblowing channels), with identity or anonymously, to members of Gülermak Ethic Committee by sending e-mail to:

ethic@gulermak.com

Breaches and violations in matters of mobbing or discrimination can be further reported to members of Gülermak Anti-Mobbing Committee by sending e-mail to:

antimobbing@gulermak.com

Gülermak’s relevant committee shall act immediately regarding the investigation, disposition or resolution of the issue, in confidentiality.

The identity of the employee reporting the violation, even if known, shall remain confidential to those persons directly involved in applying this policy, unless the issue requires investigation by law enforcement, in which case members of the organization are subject to subpoena.

Modifications

Modifications of above rules may be done only by the decision of Executive Board of Gülermak with recommendations of Managers, Directors, CEOs and Compliance Officer.

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We recognize and respect human rights within our sphere of influence

For all people, we support the right to liberty, equality, work, the highest attainable standard of health and the right to education and social security. We exercise due diligence to identify, prevent and address actual or potential human rights impacts, resulting from our activities. We take care to ensure that we don’t discriminate against employees, partners, customers or stakeholders regarding their race, colour, nationality, language, religion, ethnic or social origin, gender, age, disability, pregnancy, trade union affiliation or political opinion.

We recognize labour practices and social protection of our employees in any country where we are performing contractual activities

We will achieve fair and equitable treatment for our employees by adopting the national legislation, recognizing workers organizations and local conditions, in the country where work is performed. We will provide decent conditions of work with regards to wages, hours of work, weekly rest, holidays, health and safety, maternity protection and ability for employees to obtain a reasonable work-life balance.

We will show environmental responsibility

We will respect and promote environmental responsibility by showing a precautionary approach where threats of serious damage to the environment or climate change are caused by our activities.

We will achieve fair operating practices

We will prevent corruption and promote fair marketing and contractual practices and fair competition in all our operations. We will promote social responsibility in our value chain in regard of ethical, social and gender equality criteria in our purchasing and contracting practices. We will implement practices that promote and respect physical property and intellectual property.

We will promote community involvement with the communities in which we operate

We will consider us as part of the community and contribute to community sustainable development. This includes maintaining a transparent relationship with local government and contribution to the community in regards of the use of local employment, local suppliers and respecting and promoting cultural activities.

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We respect our earth whilst striving for the highest technology in our works

We believe that respect for the environment is an integral part of our business. We are aware of our possible impact on the global environment and we are committed to planning and executing all work processes with the lowest possible imprint on the environment.

We focus on minimizing energy consumption to avoid waste and excess consumption of materials. We work closely with our customers on the individual projects to include environmental measures and procedures from the concept design phase through to project handover, to minimize the environmental impact.

We comply with laws and agreements

Compliance with applicable laws, regulations and mutual agreements are fundamental preconditions for the way we work. We comply with internationally accepted guidelines to reduce our impact on the global environment.

We demonstrate environmental considerations

We are committed to achieving high environmental standards and minimizing the environmental impacts in the planning and design phase as well as in execution technique.

We all hold responsibility for the environment

We make sure that all our employees are aware of environmental issues and involved in environmental activities with priority to protecting the environment on both a short and long-term basis.

We urge invisible site concept

We try our best to be, for the greatest extent, invisible at our sites. We organize our sites ensuring that public can continue using the routes and facilities, the same as they were prior to commencement of our works.

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Gülermak strongly supports and handles Occupational Health & Safety (OHS) as a basic human right

Based on an understanding of the importance of human life and healthy environment as our basic principle, it is our primary objective to ensure that all of our operations provide safety-first planning, production and construction services in a healthy and safe working environment for all stake holders, employees, customers and neighbours.

In this context, our primary principles concerning OHS are the following:

Legal requirements shall strictly be monitored in all of our places of work.

All of us, whatever our rank and status within company, shall be trained in occupational health safety periodically according to regulations requirements and keep abreast with industry advances.

All staff will remain aware of the possible risks around them and will take necessary actions to gain further awareness and for mitigation.

Each member of staff has stop-work authority, having the idea “if it is not safe, don't do it”.

We pledge to make necessary resources available to provide a healthier and safer environment by revising the entire system at the management level for sustainability and further development of an OHS system compatible with other company policies we have established.

Reporting

Any employee of Gülermak or its business association can report to head of the related business unit in case of breach or violation of:

• this policy;
• local health and safety legislations;
• Gülermak’s Health Safety procedures in force.

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Gülermak is committed to achieving a seamless operation working with all employees as a single unit with unified objectives in order to provide the production and construction services that meet the needs of its employers and other stakeholders whilst providing enough resources necessary to ensure full implementation of this policy in order to meet the requirements of ISO 9001:2015.

In this context, our primary principles concerning quality are as follows:

• We understand the requirements of our employers and other stakeholder, including statutory and regulatory requirements;
• We set our objectives above standard industry requirements;
• We believe in the value of partnership;
• Together with all our employees we share the responsibility and pride of our achievements;
• We are committed to continually monitor our processes quantitatively and measure performance achieved;
• We endeavour to increase the effectiveness and improve continuously of our quality management system based on monitored results.

Gülermak respects the responsibility of management in implementing this policy to meet the commitments, including operating in an efficient and profitable manner.

Head of Integrated Management System is appointed by the Executive Board as a director responsible for quality to promote the policy and monitor the effectiveness of the system.

This policy is reviewed at least annually for continued sustainability and revised as often as may be appropriate.

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Gülermak provides construction and contracting services all over the globe.  As regards to any personal data acquired due to operations, Gülermak performs procedures for the acquirement, recording, storing, preservation, changing, rearrangement, disclosing, transfer, acceptance, accessibility, classification or prevention activities under Personal Data Processing and Protection Policy (“the Policy”).

General Policy

As per the general policy concerning the processing and protection of personal data, Gülermak:

• Requests only necessary data from Natural Persons, collected solely with their consent, in compliance with the local regulation and due to legal liabilities, for processing and/or for a specific designated purpose, with the condition to take all measures for the confidentiality of such data.
• Informs Natural Persons about the type and purpose of data request, the mode and purposes and time of recording and preservation, and possible transferees and the rights of Natural Persons.
• Raise the awareness of its employees as regards to processed data, restrictions to access the personal data of others according to their duties, and includes personal data protection commitments in labour contracts. Apart from the foregoing, Gülermak executes agreements with transferee third parties and institutions in order to ensure that the processing type and confidentiality of transferred personal data are secured.
• Gülermak keeps acquired personal data only as long as permitted by the law or it is necessary to preserve/store personal data by any means, and deletes, effaces or anonymizes all personal data according to the regulation when they are not necessary.
• Gülermak has also established all necessary rules so as to enable natural persons to execute their legal rights as regards to their processed personal data.

Fundamental Principles

As regards to processed personal data, Gülermak shows utmost attention to:

1. Compliance with law and good faith;
2. Accuracy and actuality when necessary;
3. Processing for designated, clear and legal purposes;
4. Processing to be limited, measured and associated with the purpose;
5. Preservation as long as permitted by regulations and until termination of designated time required by the purpose.

Gülermak takes all necessary administrative and technical measures in order to ensure processing in conformance with the foregoing.

The Measures Taken for the Protection of Personal Data

Gülermak undertakes the responsibility of administration and technical measures for:

• training all employees and increasing awareness about personal data protection;
• determining personal data security policies and procedures;
• investigating risks and acting on mitigation measures on threats;
• limiting the use of personal data, including the period of keeping the data;
• monitoring the security of stored personal data and protecting the same.

Right to Application by Natural Persons

Natural Persons can apply to Gülermak at any time regarding information about their personal data and Gülermak will inform them in compliance with Laws and Regulations related to Personal Data Protection.

• Learn whether their personal data are processed;
• Request information about the procedure if their personal data are processed;
• Learn the purpose of personal data processing and whether processing is performed according to the designated purposes;
• Request correction if personal data are processed incompletely or incorrectly.

In this direction, natural persons are entitled to make inquiries and to send e-mail to policies@gulermak.com about any questions or complaints. These requests will be concluded within the shortest time possible or, in any case maximum within 30 (thirty) days.

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Gülermak provides construction and contracting services all over the globe.

We are committed to develop an efficient, reliable, and high-performance Information Security Management System (ISMS). ISMS is a part of Gülermak’s Integrated Management System.

By implementing ISMS in Gülermak Ağır Sanayi İnşaat ve Taahhüt A.Ş. Polish Branch Office according to ISO/IEC 27001 standard we will reach Gülermak’s global aim to measure and verify our commitments on the availability, confidentiality, and integrity of the information, by relying on a business continuity and traceability process in the fields of application in strong interaction with the infrastructure of our suppliers, subcontractors, stakeholders and employers. This covers the activities of tender study, authority and public information management, design, planning, and progress reporting.

We endeavour to maintain our information security, while complying with the legal and regulatory requirements applicable to our activity, the contractual obligations and the requirements of ISO/IEC 27001 standard.

We are devoted to secure information, against internal and external dangers that could possibly result in loosing confidentiality, availability and integrity. Through efficient management of our ISMS we manage our, stakeholders’ and employer’ assets, and we minimise the risk of revealing information to unauthorized parties, protect them against unauthorized modification, stealing or destruction.

We will continually improve our ISMS by performing risk analyses, reviews, trainings and audits and keeping close track of our performance indicators.

Every person who works for Gülermak is responsible for acting according to the ISMS, monitoring compliance with security policy at their premises, report any incompliance and make suggestions to improve our ISMS.

Management of Gülermak is in charge of communication and ensuring everyone understands our policy and related objectives. Management also ensures that the system which is set up is planned, shared, and deployed efficiently by providing necessary human, organizational and technical resources.

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Gülermak provides construction and contracting services all over the globe.

We conduct our business professionally, with integrity and in compliance with the laws of those jurisdictions in which it operates. Our reputation for acting fairly is built on our values as a company and the values of our employees. As part of our commitment to ethical business practices, we will not tolerate acts of bribery or corruption.

This policy applies to all Gülermak employees (whether permanent or temporary), contractors, directors and managers of Gülermak, its subsidiaries and joint venture companies under Gülermak’s control, also in compliance with any laws and regulations, as the minimum obligations.  Third party acting on behalf of or in the name of Gülermak, including agents, representatives and other intermediaries, are required to act consistently with this policy.

In case of joint venture companies not under Gülermak’s control, and our joint venture partners, Gülermak take obligation to encouraged to adopt similar policy and procedures to prevent bribery and corruption.

Gülermak operates a zero-tolerance approach to bribery and corruption

Gülermak operates a zero-tolerance approach to bribery and corruption in relation to bribes (payment, offer or promise to pay or provide anything of value), gifts and hospitality, facilitation payments (small payments or fees to speed up or facilitate the performance of routine action to which an entitlement already exists) and payments to government officials.