OUR ETHICAL POLICY

Honesty

Honesty and honesty are our primary values in all our business processes and relationships. We act with integrity and honesty in our relations with employees and all our stakeholders. 

Privacy

 Confidential and private information; It includes information about Cem Ofset Matbaacılık Sanayii A.Ş. that may create disadvantage in terms of competition, trade secrets, financial and other information not yet disclosed to the public, information on personnel personal rights and information within the framework of “confidentiality agreements” concluded with third parties. Cem Ofset Matbaacılık Sanayii A.Ş. employees; It pays attention to the confidentiality and protection of private information of customers, employees and other relevant persons and organizations. Protects confidential information regarding the activities of Cem Ofset Matbaacılık Sanayii A.Ş., uses this information only for company purposes; it only shares this information with the relevant persons within the specified authorities. It is absolutely unacceptable to obtain any commercial interest by leaking any confidential information belonging to Cem Ofset Matbaacılık Sanayii A.Ş. While leaving our company, confidential information and documents that we have due to his duty and projects, regulations, etc. their work cannot be taken out.

Our Responsibilities

 Besides our legal responsibilities; to our customers, employees, suppliers and business partners, competitors, society, humanity and Cem Ofset Matbaacılık Sanayii A.Ş.

We take care to fulfill our responsibilities listed below:

Our Legal Responsibilities

All our activities and transactions are available in Turkey and abroad, We execute within the framework of laws and international law, we provide accurate, complete and understandable information to legal regulatory institutions and organizations in a timely manner. and we fulfill our obligations with this sense of responsibility.

All of our financial transactions are carried out in accordance with the laws and are taken under control and supervised by the Certified Public Accountant service. 

Our Responsibilities Towards Our Customers

 

We work with a proactive approach focused on customer satisfaction and responding to the needs and demands of our customers in the shortest time and in the most accurate way. Provides our services on time and under our promised conditions; We approach our customers within the framework of respect, honor, justice, equality and courtesy. We promptly report any violations of quality, safety and rules that occur in the business of the company or its suppliers and may have a negative impact to the senior management. Senior management evaluates and makes the necessary notification to the customer as soon as possible.

Our Responsibilities Towards Employees

We ensure that employees’ personal rights are used fully and correctly. We approach our employees honestly and fairly, and commit to a non-discriminatory, safe and healthy working environment. We make the necessary effort for the personal development of our employees, we support them in volunteering for appropriate social and social activities in which they will take part with social responsibility awareness, and we observe the balance between business life and private life. 

Our Responsibilities Towards Our Partners

 

Giving priority to the continuity of Cem Ofset Matbaacılık Sanayii A.Ş. and in line with the goal of creating value for our partners; We avoid taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability, we manage our company’s resources and assets and our working time with the awareness of efficiency and savings. We take care to increase our competitiveness and invest in areas that have growth potential and provide the highest return to the connected resource. We provide timely, accurate, complete and understandable information about our financial statements, strategies, investments and risk profile.

 

Our Responsibilities Towards Our Suppliers / Business Partners 

As expected from a good customer, we behave fairly and respectfully, we take care to fulfill our obligations on time. We carefully protect the confidential information of the people and organizations we do business with and our business partners.

Our Responsibilities Towards Our Competitors 

We compete effectively only in areas that are legal and ethical, and avoid unfair competition. We support efforts to ensure a competitive structure targeted within the society.

 

Our Responsibilities Towards Society and Humanity

 

Protection of democracy, human rights and the environment; education and charity work, the elimination of crime and corruption are very important to us. It acts sensitively as a pioneer in social matters with the awareness of being a good citizen; We try to take a role in non-governmental organizations, public benefit services, and appropriate activities on these issues. Turkey and traditions of the countries in which we conduct international projects and would be sensitive to the culture. Bribes or gifts in excess of the intended purpose, etc. we do not provide or accept products and services.

Our Responsibilities Towards Our Competitors We compete effectively only in areas that are legal and ethical, and avoid unfair competition. We support efforts to ensure a competitive structure targeted within the society. Our Responsibilities Towards Society and Humanity Protection of democracy, human rights and the environment; education and charity work, the elimination of crime and corruption are very important to us. It acts sensitively as a pioneer in social matters with the awareness of being a good citizen; We try to take a role in non-governmental organizations, public benefit services, and appropriate activities on these issues. Turkey and traditions of the countries in which we conduct international projects and would be sensitive to the culture. Bribes or gifts in excess of the intended purpose, etc. we do not provide or accept products and services.

Application basics All Company employees are required to fully comply with the situations and the principles stated below as activities that may create conflict of interest. The company does the necessary work to encourage its employees to comply with these principles. Employees do not enter into a business relationship that provides mutual or unrequited benefits with family members, friends or other third parties. For example, an employee authorized to purchase should refrain from doing business with a supplier where a family member works. Exceptional circumstances are subject to the knowledge and approval of the company’s Chairman. Employees cannot obtain any commercial benefit by leaking any information about the company from within, and cannot be instrumental in gaining interest by others. Cem Ofset Matbaacılık Sanayii A.Ş. Group employees; In non-profit organizations and universities, they can work in social responsibility and charity tasks with the written approval of the management, if they do not hinder their duties within the company. Employees of Cem Ofset Matbaacılık Sanayii A.Ş. can actively operate in any political party individually and voluntarily. Managers cannot ask their employees to do a political job or to join a party. Employees can be employed in any political party with the following conditions and written approval of the management; Employees’ participation in any political activity should not create conflict of interest with their duties, practices and approaches in the company. Employees cannot engage in any political activity during working hours and cannot take the time of their colleagues for these activities. and cannot use company resources. Employees can personally make financial or moral aid and / or donations to third parties outside the company, and take part in charity associations.

Abuse of Duty

It is unacceptable for the employees to cause harm to Cem Ofset Matbaacılık Sanayii A.Ş. Employees cannot directly or indirectly gain personal gain from the purchasing and sales activities of the company and all transactions and contracts to which they are a party. Employees cannot act or behave against morality, law and company discipline.

Use of Resources

 

Company interests are taken into account in the use of resources on behalf of the company. Company assets, facilities and personnel cannot be used outside of the company, regardless of the name and for the benefit of anyone, without the benefit of the company. The principle of “saving in all matters” is applied by all personnel. The correct use of resources for the benefit of the company also requires the correct use of time. During working hours, company employees make good use of their time and do not spare time for their private affairs during working hours. Managers cannot assign employees for their personal works. It is essential that no special visitors are accepted during working hours. Employees are required to complete interviews for compulsory visitors in a reasonable time in connection with the subject of the visit and in a manner that does not interfere with the work flow.

 Relations with Other Persons and / or Organizations with which the Company has a Business Relationship

No private business relationship can be entered into with the company’s customers, subcontractors or suppliers and other persons and / or organizations with which the company has commercial relations, personal loans and / or goods / services cannot be borrowed, and the company cannot borrow money and / or institutions with which the company has a commercial relationship. or goods / services cannot be provided. The following issues are taken into consideration in relation with customers; even if it is in favor of the customer, no transaction can be made without the knowledge of the customer, and even if it is in favor of the company, customer weaknesses cannot be exploited and the customer cannot be motivated for profit by providing incomplete or incorrect information. Company personnel cannot request or suggest gifts from other persons and / or organizations with which the company has a business relationship; no gifts, money, checks, property, free holidays, special discounts, etc. that will put companies under liability. can not accept. Personal aid or donations cannot be accepted from any person or organization that has a business relationship with the company. Regarding the subject, the Gift Acceptance and Delivery Policy is applied. 

Representation of the Company

 

Any fees that will accrue due to the duty performed in all kinds of associations, employers’ unions and similar non-governmental organizations representing the company shall be donated to the relevant institution or to the channels provided by the relevant institution. Payments made by third parties to the company employee for a seminar speaker fee or a similar service are likewise donated to the relevant institution or channels to be directed by the institution. These people receive awards, plaques, etc., which are given as commemoration of the day and have symbolic value. they can buy gifts. Cem Ofset Matbaacılık Sanayii A.Ş. It is essential that its employees do not accept gifts or benefits that may affect their impartiality, decisions and behavior, and not attempt to provide gifts and benefits to third parties and organizations that may create such effects. The principles of practice defined below regulate gift exchanges with third parties and organizations with which company employees have business relationships and determine the principles to be applied in this regard.

Application basics

Employees of the company are prohibited from receiving any kind of benefits and gifts, with or without economic value, that affect or may affect their impartiality, performance, and decision-making while performing their duties. 

Employees of the company can receive and / or give gifts with the above-mentioned characteristics or accept to be subjected to a special application, provided that the company is in line with the business objectives of the Institution, in accordance with the current legislation and that the gift is learned by the third parties will not leave the company in a difficult situation. 

Employees of the company can give and receive entertainment, treats and meals at standards acceptable in the business world, with the approval of the Board of Directors. In seminars and similar organizations attended to represent the company, as a commemoration of the day and with symbolic value, awards, plaques, etc. gifts can be bought.

It is forbidden to receive gifts or benefits that are implied or expressly linked to a provision. 

Receiving, giving or offering bribes and / or commissions are not acceptable under any circumstances.

Employees of the company are prohibited from accepting unpaid or loaned money from subcontractors, suppliers, consultants, competitors or customers, compensating travel expenses, event expenses and similar payments.

The gifts and promotional materials to be given by the company to customers and other third parties with business relations are approved by the company’s senior management. There is no need to obtain permission for the distribution of approved gifts and promotional materials.

Provided that it is in compliance with the above-mentioned conditions, the company may accept appropriate products and services as gifts and with the knowledge and approval of its senior management, products or services that are suitable for the culture and ethical values of the recipient can be given as gifts.

In exceptional cases where local cultural values require mutual gifts above the values specified in the company policy, these gifts may only be accepted on behalf of the company and with the approval of the company top management. In all cases, exchange of gifts should be done in accordance with the local culture.

Confidential Information Protection Policy 

Effective use of information, correct sharing and ensuring the confidentiality, integrity and accessibility of information in this process are the common responsibility of all our companies and employees. It is important that the management systems established for the management and confidentiality of information in our companies and that the processes applied are in harmony with each other to obtain the highest level of benefit. The following application principles; It defines confidential information for Cem Ofset Matbaacılık Sanayii A.Ş. and regulates the principles that employees must comply with regarding confidential information.

Application basics

Confidential Information, provided that they are not limited to Cem Ofset Matbaacılık Sanayii A.Ş. Intellectual property rights, all kinds of innovations, including the database written, found, developed, made or put into practice by the personnel, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and partners related information, financial information, personnel information, customer lists, product designs, know-how, specifications, identity of potential and real customers, information about suppliers, etc. It covers all kinds of written, graphic or machine-readable information. The principles to be followed regarding confidential information are as follows:

This information cannot be disclosed to third parties unless it is required to be disclosed in accordance with Official Authorities and Legislation.

This information cannot be changed, copied or destroyed. Necessary precautions are taken to ensure that information is carefully kept, stored and not disclosed. Changes on the information are recorded together with its history.

Confidential files cannot be taken out of the institution. For confidential information that needs to be taken out of the institution, the approval of the person in charge of the information or the senior management should be obtained.

Passwords, user codes and similar identifying information used to access company information are kept confidential and not disclosed to anyone other than authorized users.

Confidential information of the company is not discussed in dining halls, cafeterias, elevators and similar public places.

Company personnel know the degree of confidentiality of the information obtained in line with their duties and act in accordance with this confidentiality. When there is any hesitation in terms of the degree of confidentiality, it is treated according to the higher confidentiality class and the opinion of the relevant manager is taken when necessary.

In case of sharing information with third parties and / or organizations for the benefit of the company, a confidentiality agreement must be signed or a written confidentiality commitment must be obtained from the other party in order to guarantee the understanding of the responsibilities of these persons and organizations regarding the security and protection of the shared information. 

No unfounded statements and / or gossip about persons or institutions can be made.

The wages, benefits and similar personal information of the personnel that reflect the company policy and are personal, are confidential and cannot be disclosed to anyone other than the authorities. Personnel information is sent personally. It is strictly forbidden for staff to disclose this information to others or to pressure other employees to disclose this information.

Policy for Creating and Maintaining a Fair Work Environment

Cem Ofset Matbaacılık Sanayii A.Ş. regards the creation and maintenance of a fair working environment as one of its top priorities. It is aimed to increase the success, development and loyalty of the employees by creating a fair, respectful, healthy and safe working environment that complies with all relevant laws and regulations. The following principles of practice are the basis for establishing and maintaining a fair working environment at Cem Ofset Matbaacılık Sanayii A.Ş.

Application basics

Company practices are in accordance with all applicable laws and regulations regarding employment and working life. Company employees also fulfill all legal requirements within the scope of their activities and act in accordance with legal regulations.

Cem Ofset Matbaacılık Sanayii A.Ş. human resources policies and practices; recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. it ensures that all other applications are fair.

It is unacceptable to discriminate among employees working within the organization on the basis of language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons.

By creating a positive and harmonious working environment that supports cooperation in the company, conflict environments are prevented, and it is ensured that people with different beliefs, views and opinions work in harmony.

Private lives and personal spaces of employees are respected.

Communications between persons cannot be violated by persons who are not parties.

 Even if it is recorded in accordance with the law, it is forbidden to give / disseminate / seize personal data illegally.

 Personnel personal information arising from the nature of the business relationship and that may be required in the continuation of the workplace are not used outside of their purposes and are not shared with third parties without the consent of the persons.

Private and family lives of all employees are respected.

 In addition to all kinds of immunities of the employees, physical, sexual and emotional immunities are also observed. Any violation of the immunity of the employees by physical, sexual and / or emotional harassment is against the law and ethical rules, and this crime is not tolerated by the company. The purpose of this practice is to ensure that employees work in a work environment where their physical, sexual and emotional immunity is protected. Violation of a person’s bodily immunity through sexual acts and / or sexual harassment of a person without physical contact is defined as sexual harassment. According to this; It is forbidden to exhibit any behavior that can be considered within the scope of this definition. In addition, those who complain and report about any harassment or behave negatively against those who help during the investigation are also not tolerated. No employee can demand a privileged practice due to different gender, religion, language, race, and cannot give privileges to anyone or be subjected to a special application. It is unacceptable to make or receive concessions by taking advantage of differences such as gender, religion, language, race. It is ensured that the workplace physical working environment and conditions are healthy and safe for all employees.

RESPONSIBILITIES OF MANAGERS

 

The managers of Cem Ofset Matbaacılık Sanayii A.Ş. have additional responsibilities beyond the responsibilities defined for the employees. Accordingly, managers; ensuring the establishment and maintenance of a corporate culture and work environment that supports ethical rules, Setting an example for the implementation of ethical rules, educating employees about ethical rules, Supporting employees in conveying questions, complaints and notifications about ethical rules, Providing guidance on what to do when consulted, all notifications to ensure that the business processes under his responsibility are structured in a way that minimizes the risks related to ethical issues and to apply the necessary methods and approaches to ensure compliance with ethical rules.

OTHER RESPONSIBILITIES

Company top management; They are responsible for the effective implementation of the Business Ethics Rules and the creation of a culture that supports it. Business Ethics Rules and any related policies are announced to the company employees by the Human Resources Department with the approval of the Chairman of the Board of Directors.

 Human Resources, with the cooperation of Senior Management;

Providing trainings at certain periods in order to inform the employees about the rules, to ensure the understanding of the policies and rules, and to ensure that this issue is constantly communicated with the employees,

Ensuring that those employed in the company read the ethical rules, are informed about this issue and sign the relevant documents,

To guarantee the confidentiality of complaints and notifications made within the framework of the Code of Ethics and to protect individuals after notifications,

To ensure the job security of employees who make a notification

Ensuring that complaints and notifications are investigated in a timely, fair, consistent and sensitive manner, and resolutely taking necessary actions as a result of violations,

Ensuring that the employees receive training on existing rules and revisions at least once a year,

They are responsible for evaluating the risks that may occur and revising the relevant policies when necessary. 

RESOLUTION OF NON-COMPLIANCE WITH THE CODE OF ETHICS 

Those who violate the Code of Business Ethics or Cem Ofset Matbaacılık Sanayii A.Ş.’s policies and procedures will be subject to various disciplinary sanctions that can reach the level of asking them to leave their job if necessary. Disciplinary sanctions will also be applied to those who approve, direct or have knowledge of inappropriate behaviors and acts that cause violation of the rules and do not make the necessary notification appropriately.