Ethical Principles

2. OUR BUSINESS PRINCIPLES

• The prestigious image and corporate brand that INTECRO has created as a result of its activities in its past is its most valuable asset. In order to protect and develop INTECRO’s corporate reputation, the basic business principles that all INTECRO employees across the Company must comply with in their activities are listed below.
• The expectation of INTECRO from all its employees while continuing its activities;
  Understanding and adopting the company’s values, ethical principles and acting in accordance with INTECRO’s way of doing business.

2.1. Honesty

• INTECRO sees the values of accuracy, transparency and high business ethics above all in all its activities; expects all parties with whom it does business to act in accordance with the same values.
• INTECRO as one of Turkey’s most reliable and reputable institutions, in business relationships business partners, employees, suppliers, competitors, the environment, against society and humanity, makes no behavior that would undermine mutual trust.

2.2. Privacy

• Confidential information is financial, strategic, technical, commercial, all kinds of information belonging to the company and not known by third parties, which may cause damage to the company and / or its stakeholders or benefit others, especially regulated within the scope of confidentiality agreements with third parties. topics and similar information.
• INTECRO employees are expected to take care to protect the information of INTECRO and all its stakeholders. Employees only share this information with the relevant persons within the specified authorities.
• Confidential information is not shared with third parties when leaving INTECRO. Employees are obliged to submit all kinds of documents or electronic copy documents that they receive during the working period and belong to INTECRO.
• Employees who have recently joined INTECRO cannot share confidential information about their previous employers within INTECRO. All official statements are announced to investors, partners and the public simultaneously, as much as they need to be known, through units determined by INTECRO. Person or persons among the employees who are not authorized by INTECRO management; He should not act in the scope of any explanation, declaration or commitment to the public or to third parties, companies, institutions and organizations.
• INTECRO employees are expected to protect confidential financial information attributable to INTECRO, trade secrets, information and documents related to personnel rights or agreements made with business partnerships that may weaken the competitive power of INTECRO, and such information and documents, and to protect the confidentiality of such information.
• INTECRO employees are expected to refrain from sharing information obtained or owned with unauthorized persons, internal or external authorities, or using it for speculative purposes (directly or indirectly).
• INTECRO employees are expected to refrain from using and sharing non-public information belonging to the institutions, organizations, companies and their customers with whom they do business, for purposes other than the specified purposes and sharing them with third parties without obtaining necessary permissions.

2.3. Fair Working Environment

• INTECRO believes in and supports the rights and freedoms of people wherever it operates.
  Accordingly, INTECRO does not discriminate under any circumstances based on the ethnic origin, gender, race, nationality, economic status, religion and other beliefs of individuals. This also applies to recruitment and promotion, the working conditions provided, and all relationships with customers, suppliers, governing bodies, shareholders and partners of any kind.
• INTECRO is obliged to ensure that the working conditions, the products and services they produce are suitable for human health and safety.
• Every employee has the right to receive fair, polite and respectful treatment from his / her subordinates, superiors and colleagues. By creating a fair, healthy and safe working environment where employees are respected and complied with all relevant legal regulations, the performance, development and loyalty of employees will be increased.

2.4. Compliance with Law

• All INTECRO companies are obliged to comply with the laws of the countries in which they operate. Our employees are not allowed to do unlawful work, thinking that it will serve the company or personal interests.
• If there is any suspicion in the legal field about the work done, the matter is immediately brought to the attention of the Human Resources Department or the INTECRO Legal Unit with the guidance of the HR department.

2.5. Human Resources

The indispensable basic principles of INTECRO in order to ensure quality human resources management are summarized below:

• INTECRO observes cooperation between employees in the working environment.
• INTECRO bases on the qualifications and skills required by the job as a basic principle while recruiting and promoting its employees.
• INTECRO ensures that its employees are in a position where they can use their potential, create value and contribute to the achievement of Company goals.
• INTECRO ensures that employees’ personal rights are fully used.
• INTECRO approaches its employees honestly and fairly, ensures that they work in a non-discriminatory, safe and healthy work environment.
• INTECRO creates the necessary training and development opportunities within the framework of its resources in order for its employees to develop themselves in the best way and to do their jobs better.
• All issues that may be of interest to INTECRO’s vision, mission, goals, activity results are regularly shared with employees.

2.6. Quality and Continuous Improvement

• It is INTECRO’s basic quality principle to define customer needs and expectations, to offer solutions and to fulfill them completely, to continuously improve the product and service quality in line with customer and market requirements, and to create value for all stakeholders.
• INTECRO creates an effective quality management system with the principle of “doing the job right at the first time”, ensuring that these goals are achieved with measurable goals, effective monitoring, evaluations and actions.
• The quality of the products and services offered to its customers is always under INTECRO assurance.

2.6.1. Continuous Improvement (KAIZEN)

Kai in Japanese: Change, Zen: good means better. Kaizen, which is formed by the union of these two words, means “continuous improvement that covers everyone. KAIZEN also expresses a philosophy and a way of life: “To make continuous efforts at home, at work and in social life so that each day is better than the previous day.”

The most basic philosophy of INTECRO regarding quality, existence and sustainability issues is KAIZEN.

Similarly, it is expected that the most basic approach of all members of INTECRO, including its employees, partners, management officers and shareholders, will coincide with KAIZEN.

The source of the continuous improvement process is the Kaizen philosophy.

Continuous improvement process; It is for everyone who works as thoughts and behaviors to open every situation to discussion and then seek ways to improve it.

If we think of Kaizen philosophy as an umbrella, it is possible to see the following units under this umbrella.

• Customer orientation
• Total quality control
• Quality circles
• Suggestion system
• Automation
• Discipline at work
• Total efficient maintenance
• Kanban
• Quality improvement
• Just in time production
• Zero error
• Small group activities
• Employee management participation and employee collaboration
• Productivity improvement
• New product development

All members of INTECRO, including employees, must consider and apply the following Kaizen propositions and rules.

• In recent years, the main goals of businesses have been to deliver a wider variety of products to customers in a shorter time, with better quality and cheaper, in parallel with the changes in the structure of the products as a result of diversified consumer demands. Responsibility should be taken to meet this need.
• Businesses cannot be successful without reaching their “quality”, “cost” and “deadline” targets.
• All other management functions of businesses should serve three goals: “quality”, “cost” and “deadline”.
• Quality should not be limited to the quality of products and services. The satisfaction of employees, suppliers and customers should be in the first place.
• Every individual should take responsibility in order to increase the quality of workplace infrastructure facilities and facilities, life culture in the workplace, and the quality based on individual rights, and by identifying and sharing the problem, it should be a part of the solution, not the problem.
• It should not be forgotten that continuous improvement (Kaizen) is a basic concept that guides good management.
• Management philosophies, theories and tools developed and used over the years have been brought together and gathered under a single concept. It has developed the understanding of KAIZEN.
• On the basis of continuous improvement; Continuous, minor improvements to the process, especially by employees, are very important and must be implemented continuously, never underestimated.
• Continuous improvement prioritizes people first, then production and process, It should be taken into consideration that continuous improvement is not a hardware, software or item, it should be adopted that it will make sense only as long as it is applied by individuals, keeping in mind that it is a management system that supports people’s work and efforts towards the process.
• No process, no flow is so perfect that little improvement can be made. Searching for improvement opportunities is everyone’s job, especially those working in that job.
• Wherever and whenever there is an improvement, this will ultimately lead to an improvement in quality and efficiency. It should not be forgotten that quality is everything that can be improved.
• The most important factor that increases competitiveness is the Total Quality phenomenon.
• As the basic element of Total Quality Management, the adoption of the concept of Kaizen (continuous improvement) and its adaptation to the business structure gains importance.

Kaizen has 7 principles. All employees must perform their business life cycles based on these principles.

1. Accept the problem.
2. Choose projects that don’t require a lot of money.
3. Look first at “our” problems, not “theirs”.
4. It should not be seen as the only measure of economic interest.
5. Set priority. The project; quality, cost, distribution etc. Execute based on principles.
6. After Defining the Problem, the Plan, Apply, Check, Take Action (PDCA) cycle should be followed.
7. Use the right solution tools.

KAIZEN’s approach to problems is in the form of Welcome Problems. Because there can be no development where there is no problem. However, if possible, those who define the problems are expected to present the problem not alone, but with a solution proposal.

2.7. Effective Use Policy

INTECRO and our group companies affiliated with INTECRO adopt as a basic principle to prevent waste in the use of resources in their activities and projects they carry out.

2.8. Environment

INTECRO aims to carry out its activities in a way that does not harm the environment.
INTECRO, in order to protect natural life and prevent environmental pollution;

• Runs waste management programs,
• Ensures efficient use of energy for a sustainable environment,
• Increases the use of recyclable resources,
• Shows the necessary effort to reduce the consumption of natural resources,
• Monitors environmental legislation up-to-date, takes necessary actions by evaluating conformity
• It makes maximum effort to raise awareness of its employees, customers, suppliers and the general public about the environment.
• It should keep communication within the institution strong.

2.9. Occupational health and Safety

• In INTECRO, “No job is urgent and important enough to endanger the life safety and health of a person.
• INTECRO sets measurable goals by putting the “Zero Accident and Injury” philosophy at the head of all business plans in order to prevent / minimize occupational accidents and occupational diseases, and ensures that these goals are achieved with effective monitoring, evaluations and actions.
• INTECRO aims to plan, continue and complete its activities in full compliance with national and international regulations, contracts, customer requirements and other conditions within its activities.
• All employees are continuously trained, informed and act in accordance with the rules and instructions set for this purpose and take the necessary measures in order to develop and maintain the “Occupational Health and Safety” principles.

2.10. Public Activities

• INTECRO conducts its relations with official institutions and organizations within the framework of ethical principles, in accordance with laws and regulations.

2.11. Bribery and Corruption

• Employees; They will not offer or promise any direct / indirect personal, financial or other advantage to obtain a business / unrelated advantage from a third party. In addition, employees should not accept a similar advantage in exchange for preferential treatment to a third party. They should also avoid activities and behaviors that would create suspicion and impression of engaging in such behavior.
• Employees should be aware that gaining or offering benefits to the other party in order to influence the other party’s decision may also result in legal penal sanctions. Everything that has value for the beneficiary party, such as improper interest, employment for relatives and consultancy agreement, is considered within this scope.

2.12. Discrimination and Harassment

• INTECRO respects the personal dignity, privacy and personal rights of all employees and is determined to keep the workplace free of discrimination and harassment. Therefore, employees may not discriminate on the basis of origin, nationality, religion, race, gender, age or sexual orientation, or engage in any physical or verbal harassment based on the above or for any other reason.
• Those who feel they are working in a workplace where these principles are not applied are encouraged to discuss the situation with the Human Resources department.

2.13. Public Relations

• Giving a statement to any broadcasting organization, making an interview, seminar, conference, etc. Participating in places as a speaker and determining whether a fee will be charged depends on the approval of the Company Senior Management. Apart from this, no personal gain can be obtained from these activities in any way.

2.14. Relations with the Association, Club, Political Party

• Employees of the company cannot financially support political activities on behalf of the company, even using their own financial means, and cannot participate in activities on behalf of the company, except for professional and sectoral associations and clubs. During his term of office, he cannot actively operate in any political party.
• It cannot operate in any institution, association, club or political party in a way that may affect company activities or disrupt the working atmosphere in the workplace regarding these matters. Managers cannot ask their employees to engage in a political activity or to become a member of a party, association, institution or club.
• Employees of the company can provide financial or moral assistance to third parties outside the company, make donations and take part in charity associations. Cannot use the Company name in donations.

2.15. Fraud, Protection of Company Assets

• Employees should not be involved in any fraudulent activity in connection with INTECRO’s or a third party’s property, assets, financial reports and accounts. When this situation is detected, INTECRO acts in accordance with the law.
• INTECRO’s financial records are the basis for the company to manage its business and fulfill its responsibilities towards its stakeholders. Therefore, all financial records must be smooth and consistent with accounting standards.
• All employees should try to protect INTECRO’s assets from loss, damage, abuse, theft, fraud, embezzlement and destruction. This obligation includes all tangible and intangible assets including INTECRO’s information and information systems.
• As permitted by applicable laws, the company has the right to monitor and control how its assets are used by its employees. This includes tracking and control of electronic mails, information, data and files kept on the corporate network.

2.16. Legal Controls and Policy Controls

• As INTECRO, it is obliged to act transparently and honestly in accordance with the audit ethics in all legal and principle audits. A senior manager is immediately informed for all possible problems.

2.17. Reporting Non-Compliance, Unlawful or Unlawful Behavior

• It is the inalienable personal responsibility of every employee to “do the right thing” and apply the highest standards of integrity. Whenever in doubt, employees should always take this Ethical Principles as a guide.
• It is the responsibility of every employee to comply with all of these rules and to consult their manager or Human Resources department when necessary. If appropriate, violations can also be directly forwarded to higher-level individuals, depending on the content of the issue to be reported.
• In case of failure to comply with these rules, employees may be faced with judicial investigation and criminal sanctions, depending on the application of the disciplinary regulation and the conditions, which may result in dismissal.
• All complaints will be properly investigated. When these notices are made in good faith, INTECRO prohibits revenge against the reporting employee and likewise protects the rights of the accused.

2.18. Use of Time

• It is essential that non-business visitors are not accepted during working hours. Company employees are obliged to complete their interviews for compulsory visitors in a reasonable time in connection with the subject of the visit and in a way that does not interfere with the work flow.
• It is necessary to pay attention to the same issues when using time outside the company (marketing activities, customer visits, visits to third parties and official institutions, purchasing, service, business or educational travel, meetings, etc.).
• Employees cannot be forced to work overtime or kept at the factory.

2.19. Compliance with Laws, Regulations and Rules

• INTECRO and its employees respect the law. The application of all applicable laws and regulations cannot be compromised. In addition, employees must adhere to internal rules and regulations as necessary.
• Our employees can receive the information they want about their legal rights from the Human Resources Department whenever they want.

2.20. External Management / Partnership

• The employee should refrain from activities and activities outside the company that would conflict with his / her responsibilities in INTECRO, damage the reputation of INTECRO or otherwise conflict with the interests of INTECRO.
• When employees are in doubt about the appropriateness of an activity, they should contact the Human Resources Department.
• The following positions or activities can only be accepted or carried out with prior permission from the CEO.
• Board Membership, Manager, Employee, Partner, Consultant
• A position or activity that would conflict with INTECRO’s interests or individual responsibilities will not be permitted.
• If it is not a position or activity requested by the company, employees should do their external activities in their own free time, at their own risk and with their own financial means.

2.21. Child Labor

• Child labor is out of the question in INTECRO.

2.22. Family, Relative and Employee Relations

• Recruitment of close family members and spouses of employees as employees or consultants depends on the condition that this decision is made based on the qualifications, performance, competence and experience of the employees and that there is no reporting relationship between the employee and his relative.
• These fair employment principles apply to all areas of employment such as remuneration, promotion and transfer, and also in cases where kinship is born after the employee’s employment.
• Provided that their qualifications are equal to other candidates, employees’ children may be given priority in short-term recruitment, such as internships, training periods, vacation work and the like.

Practices in Family, Relative and Employee Relations;

• The relationship established between employees is a business relationship. Familiarity and relative of the employee does not change the way the employee addresses and behaves.
• Employees do not behave in the business environment beyond the limit of business friendship.
• Working in a subordinate-superior relationship or working in the same department depends on the approval of senior management.
• Employees cannot behave in any way (disrespect, ridicule, humiliation, harassment, etc.) that will not be welcomed by their colleagues.
• No discrimination is made between employees (appearance, physical disability, religion, gender, language, race, etc.).
• Employees should not make propaganda on personal matters such as politics, religion, or race, or make pressure to influence the opinion of the other party. Employees cannot ask their colleagues to engage in political activity or to join a party.
• Employees cannot keep weapons, sharp, piercing tools, pocket knives and similar dangerous tools within the company.
• Violent behavior and / or aggressive attitude and / or threatening speech and behavior are not acceptable within the company. In these cases, the relevant manager is informed.
• Employees; does not make unprovable statements and / or gossip about colleagues, customers and company-related institutions.
• Gambling and betting are not allowed within the boundaries of the company.
• You cannot come to the company under the influence of alcohol and recreational substances. These substances are not used within the company.

2.23. Relations with Customers / Subcontractors, Suppliers and Other Companies and Persons with which the Company has a Commercial Relations

• • It is essential that personal relations with all customers, suppliers, subcontractors and other sources that have business relations with INTECRO are not outside of business principles.
  • Giving advantage to any party by using personal relationships will not be considered an acceptable situation.
  • No private business relationship can be entered into with the company’s customers / subcontractors / supplier companies and other companies and persons with whom the company has commercial relations, personal loans / goods cannot be borrowed and loan money / goods to customers / subcontractors / suppliers and other companies and persons with whom the company has a commercial relationship. cannot be given.
  • Apart from that, on behalf of the person; The purchase of personal goods or services from the customer / subcontractor / supplier company and other companies and persons with whom the company has a commercial relationship, either far below its value or without paying any price, is considered as a gain and is considered within the scope of the disciplinary regulation.

Applications in Customer Relations;

• Ensuring customer satisfaction is the first priority of all employees, even if it is not in the field of duty. Issues that cause customer dissatisfaction are handled with priority.
• Maximum effort is made to resolve customer complaints as soon as possible. If the employee cannot resolve the complaints within his / her field of duty, he / she informs the manager.
• Even if it is in favor of the customer, no transaction can be made without customer knowledge and approval.
• Incomplete or incorrect information is not given to the customer, even if it is in favor of the company.
• Errors made in any transaction related to the customer are not stored. A solution is sought by informing the manager. The customer is also informed about the error.
• The customer’s personal information (contact information, marital status, profession, education status, etc.) cannot be given to a second person or company without the consent of the customer (except for written requests from official institutions).
• The relationship established with the customer is a company-customer relationship. Whether the customer is a acquaintance, spouse, relative or permanent customer does not change the behavior of the employee.
• No behavior that will not be welcomed by the customer (disrespect, ridicule, humiliation, harassment, insistence, etc.). In the face of any negative situation that may be experienced with the customer, the employee informs the manager about the issue without having to argue with the customer.
• No discrimination is made to the customer (appearance, physical disability, religion, language, race, gender, etc.).
• No comments or opinions are made on personal matters such as politics, religion, or race in meetings with the customer.
• The units determined in accordance with the business rules make the collection from the customer. No employee can receive money or negotiable documents from the customer.
• Employees; It cannot make any payments on behalf of the customer.

2.24. Modern Slavery

• Our company does not take part in any field and does not allow “modern slavery”, which is defined as “slavery and forced or compulsory labor” or “human trafficking”.

3. EXTERNAL RELATIONS WITHIN INTECRO

• The following basic principles guide INTECRO’s relations with its stakeholders:

3.1. Communication with Stakeholders

• To raise and represent the reputation of the INTECRO brand before the society,
• To benefit from comments and recommendations by keeping the means of communication with stakeholders open, to ensure the sustainability of positive relationships,
• To keep his views away from being personal in public sharing,

3.2. Stakeholder Relations

• To protect the rights and interests of stakeholders as stipulated in laws,
• To make maximum effort to create value in return for the resources provided by stakeholders, to provide profit share to stakeholders or to channel these resources to investments,
• Ensuring that all issues related to group companies are shared with stakeholders and the public fully, urgently and accurately,
• To ensure that the group companies are managed within the framework of the same principles of honesty and integrity as they have been managed since INTECRO was founded, to target sustainable growth and profitability, to create awareness of managing company resources, assets and time effectively.

3.3. Relations with Government Institutions

• To comply with the legislation of the countries where operations are operated or are considered to be conducted
• To manage, record and report all operation and accounting systems in accordance with the laws.

3.4. Social responsibility

• To support efforts that will contribute to economic and social development,
• To be sensitive to issues of public concern and to support improvement efforts.

3.5. Customer relationship

• To create value for customers, to meet their needs and demands at the highest level,
• To produce quality products and services, to adopt consistent policies,
• To create an atmosphere of long-term trust in our relations with customers,
• Aiming to be the preferred brand among customers by increasing customer satisfaction after sales and after sales,
• Avoiding misleading or incomplete information to customers.

3.6. Supplier, Dealer, Authorized Dealer and Authorized Service Relations

• Acting in partnership with our suppliers, dealers, authorized dealers and services while creating value in business relations,
• To establish open, direct and proper communication with our suppliers, dealers, authorized dealers and services,
• Deciding on the basis of objective criteria when choosing our suppliers, dealers, authorized dealers and services,

3.7. Competitor Relations and Competition

• Avoiding, under all circumstances, from behaviors that are directly or indirectly preventing, deflecting, or limiting the competitive power of competitors or other persons or companies, except as permitted by law,
• Avoiding abuse of this dominance in places where market dominance is achieved alone or with other companies,
• Avoid exchanging information or entering into discussions with competitors to create competitive conditions. Associations, boards, chambers, professional associations, etc. or to avoid all kinds of statements, discussions or methods mentioned above that may be misunderstood or interpreted in any kind of organization outside the company where private discussions are taking place and the Company is represented.

3.8. Relations with the Media

• Employees must obtain Senior Management approval before sharing any information about the company and business with the press. In relations with the press, all kinds of statements and behaviors that may damage the reputation of the company, cause negative evaluation or lead to speculation are avoided.
• Giving a statement to any broadcasting organization, making an interview, participating as a speaker in places such as seminars or conferences, and determining whether a fee will be charged depends on the approval of the Senior Management.

4. RESPONSIBILITIES OF EMPLOYEES

The primary responsibility of INTECRO employees is to make sure that the name “INTECRO” is synonymous with professionalism, integrity and honesty and take it to the next level. In this context, the following behaviors are expected from INTECRO employees:

• Always abide by the law,
• To perform their business and transactions within the limits of their given authority, to apply to their managers in matters that exceed their authority,
• Fulfill their duties within the framework of basic moral and human values,
• To act fairly, in good faith and understanding in all relations for the purpose of common benefit
• Whatever happens; Refrain from accepting bribes from any person or organization or bribing any person or organization from unfair gain,
• To act in compliance with all principles and practices that support the relevant rules of business ethics in all works,
• Avoid any behavior, statement or written statement that binds the company without permission,
• Avoiding behavior that would disturb or harm other employees, or disrupt the harmony of the work environment,
• Protection of all assets of the company, including the document and information systems, from damage, abuse, theft and sabotage,
• Avoid using working hours and company resources directly or indirectly for personal gain and / or for political activity or benefit.

4.1. Asset and Information Management

4.1.1. Use of Company Resources

Comprehensive INTECRO Policies created on the use of company resources are explained below:

4.1.1.1. Internet and Electronic Mail Policy

• Employees should only use internet access and electronic mail receiving / sending for business purposes,
• INTECRO’s internet access and electronic mail system is a company resource and INTECRO has the right to read, monitor and copy the internet usage and e-mails,
• Employees must take sufficient care not to disclose confidential information and to obtain illegal information.

4.1.1.2. Compliance with Information Technology Policies

Employees are obliged to comply with Information Technologies policies at all times. Below; Policies including but not limited to:

• Not using unlicensed software,
• No compromises on connection security,
• Not using or downloading adult content, gambling & betting, harmful and illegal sites.

4.1.1.3. Equipment and Equipment

• Office equipment, office furniture, fax machines, computers, software, hardware, equipment and similar equipment belong to INTECRO and cannot be used for personal purposes.

4.1.1.4. Personal Affairs

• INTECRO employees cannot use INTECRO facilities to carry out their private business.

4.1.2. Intellectual Property Rights

• To ensure that all legal processes are initiated urgently and that the procedures for ensuring the intellectual property rights of newly developed products, processes and software are completed,
• Avoiding the deliberate unauthorized use of patents, copyrights, trade secrets, brands, computer programs and other intellectual and industrial property rights belonging to other companies.

4.1.3. Knowledge Management

• Ensuring that all legally required records are kept,
• Avoiding responding to confidential information requests by third parties regarding the business of the company without the approval of the senior management,
• To pay attention to the fair presentation of the financial statements and reports presented by the company.

4.1.4. Security and Crisis Management

• To take the necessary measures to protect the company employees, information and information systems and administrative facilities from natural disasters,
• To create crisis planning through natural disasters and such cases through emergency crisis management organization and to ensure that the business continues with the least damage during the crisis,
• Taking all personal precautions to prevent theft or loss of company assets.

4.2. Avoiding Conflict of Interest

• Conflict of interest is defined as the confrontation between the employee’s family, friends, possible interests of the people and institutions with whom they are in contact with the interests of the company, which prevents the employees from performing their jobs impartially.
• INTECRO expects its employees to avoid possible working conditions that may conflict of interest, and in case of a potential conflict of interest, the employee immediately informs his / her manager.

4.2.1. Avoiding Related Party Transactions or Personal Interest Transactions

• Avoiding gaining unfair gain and income for third parties, related parties or anyone by taking advantage of its position or power,
• Avoiding any conflict of interest regarding the job undertaken,
• Avoiding stealing or distracting other employees’ time during the performance of the work, and avoiding situations that prevent them from concentrating on the main job,
• To inform the relevant manager immediately when there is an employee who has a first-degree family relationship with a customer or supplier who is in a decision-making position in the same sector,
• When employees become shareholders in another company or investment, they must disclose this. Employees are urgently required to report any status changes in this context or similar characteristics that may be perceived as a conflict of interest to at least two senior managers.

4.2.2. Receiving and Giving Gifts

When contacting people and institutions that intend to establish or continue a business relationship with INTECRO:

• Accepting or offering any gift / activity that may violate the environment of independent thinking and decision-making is avoided, except for gifts and related activities based on business tradition, general culture and customs. Gifts that are not worth 100 TL (or its equivalent amount) or more, such as the calendar, gift baskets or chocolates, etc. sent on the New Year’s Day are not included in this scope. On the other hand, regardless of the nature of the gifts, if the gift is not accepted, the human resources department is informed when there are issues that are thought to affect the communication with the relevant party negatively. Human resources will inform the decision about the acceptance of gifts.
• Requesting discounts or materials that may be perceived as inappropriate from suppliers, dealers, authorized services, customers, group companies or third parties, outside of commercial practice; or offering the same to third parties; or, if offered, refrains from accepting.

4.2.3. Doing Business with INTECRO after Termination of Employment

• Doing business with INTECRO after the termination of employment, with INTECRO; It is defined as establishing a company personally, owning a share in a company, undertaking contractual commitment, consulting, obtaining representation, opening a dealership or engaging in similar commercial activities. It is not allowed to enter into such commercial relationship until 2 years have passed since the person concerned left INTECRO.

4.2.4. Information Leakage

• Employees are required to refrain from transmitting all kinds of confidential information belonging to INTECRO to third parties, relying on such confidential information and the purpose of obtaining commercial income from the purchase or sale of securities directly / indirectly by third parties. Employees’ behavior contrary to this principle will not be binding on INTECRO in any way. The employee will be personally responsible for all consequences of acts contrary to this article. They also need to be fully aware that confidential information trading is a violation of the law. In addition, violation of this article will also constitute a violation of the employment contract of the employee, and such behavior should not be performed under any circumstances.

4.3. Records and Files

4.3.1. Accurate and Complete Business Files

• Employees must act in good faith in order to prevent any deviation from the accuracy of information in INTECRO’s records and documents, in their internal and external relations or in the use of any communication channel, including telephone and electronic communication tools.

4.3.2. Financial Reporting

• All INTECRO resources, assets, liabilities and documents are recorded in accordance with the provisions of the relevant legislation and Generally Accepted Accounting Standards.

4.3.3. Collaboration with Auditors

• INTECRO employees; INTECRO should cooperate with internal and external auditors during the examination of its books, records and activities.

5. MANAGERS RESPONSIBILITY

In addition to the defined responsibilities of INTECRO managers; they have additional responsibilities.

These :

• Creating and maintaining a working environment and corporate culture that supports ethical principles,
• To set an example while applying ethical principles, to educate its personnel about ethical principles,
• Supporting employees to express their questions and complaints / concerns regarding ethical principles,
• When consulted on any matter related to ethical principles, guiding and carrying the issue to the Ethics Representative or Legal unit when deemed necessary
• To structure business processes in a way that minimizes ethical risks and to implement the necessary methods and approaches to ensure that ethical principles are followed.

6. OTHER LIABILITIES

• The Board of Directors or the CEO is responsible for the effective implementation and support of the company-specific rules of INTECRO ethical principles or the Business Ethics created in this context.
• All policies related to the Ethical Principles are reviewed, revised, documented by the Human Resources and / or Risk Management and Compliance department upon the recommendation of the Board of Directors or the CEO, and the revisions are announced to INTECRO upon the approval of the Board of Directors or CEO.

Responsibilities of Human Resources and / or Risk Management and Compliance department:

• To inform employees about the Ethical Principles, to provide periodic trainings to better understand the policies and rules, to communicate with employees on this issue,
• To make sure that newly employed personnel read the Ethical Principles, inform them about this issue and make sure that they sign the Employee Declaration,
• Ensuring that employees sign the Business Ethics Compliance Form at the beginning of each year and updating their declarations,

Board of Directors or CEO responsibilities:

• To ensure that the confidentiality of complaints and notifications are made within the framework of Ethical Principles and to protect the confidentiality of the persons concerned with such complaints,
• To provide job security to employees who make complaints and notifications,
• Ensuring that complaints and notifications are investigated in a timely, fair, stable and sensitive manner,
• To take the necessary actions without hesitation against the rule violation.

7.NO FOLLOWING THE ETHICAL RULES

• Those who do not comply with the principles of business ethics and / or company policies and procedures are subject to disciplinary investigation leading to the termination of the employment contract. The investigation disciplinary process is also applied to those who, despite being aware of it, do not report the potential violation, do not initiate the necessary process, as well as approve or manage inappropriate behavior that violates ethical principles.
• Non-Retaliation Policy: Employees cannot be subject to retaliation for reporting in good faith a suspected violation or actual violation of the ethics policy. Retaliation is a serious violation of the Ethics Principle and must be reported immediately.

7.1. Ethics Representative

• Ethics Representative has all complaints and notifications and research responsibilities regarding violations of INTECRO’s Ethical Principles and related policies. Ethics Representation reports directly to the CEO. The appointment of the Ethics Representative is made by the CEO or the Board of Directors.

7.2. Working Principles of the Ethics Representative

Unless specifically stated, Ethics Representative has been appointed as the Human Resources Department and its related officers. Ethics Representation carries out its activities within the framework of the principles stated below:

• Keeps the complaints / notifications and the identity of the complainant confidential,
• Conducts the investigation as confidentially as possible,
• At the end of the investigation, it takes all necessary measures to protect the personal rights of the employee who is being investigated due to the possibility that the complaint is unfounded
• It has the authority to directly request information, documents and evidence regarding the investigation from the relevant department. Analyze all information and documents within the limits of investigation,
• Investigation processes are recorded in writing. Information, evidence and documents are added to the records,
• The investigation is handled urgently and resolved as quickly as possible,
• The recommendations of the Ethics Representative are implemented quickly,
• Relevant departments and authorities are informed of the result,
• The Ethics Representative member acts independently without being affected by the organizational hierarchy while performing his / her duty. There is no pressure or suggestion in this regard,
• Ethics representative forwards the notifications to the ethics committees / representatives of the relevant companies in order to inform them. Notifications regarding the executive staff and senior management are not reported to the relevant company.
• If “Expert opinion” is deemed necessary by the Ethics Representative, experts may be consulted to ensure that confidentiality principles are not violated during the investigation and necessary precautions are taken.

8.ZERO TOLERANCE POLICY REGARDING VIOLATIONS OF THE RULES

INTECRO adopts a zero tolerance approach to violations of the Code of Ethics, failure to report the policy violation correctly or retaliation against those who report. INTECRO may enforce disciplinary provisions against employees who violate these rules or retaliate against those who report.