OUR ETHICS POLICY

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OUR ETHICS POLICY

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

PRIVACY: Confidential and private information; It covers information about Cem Ofset Printing Industry Inc. that may create a disadvantage in terms of competition, trade secrets, financial and other information that has not yet been disclosed to the public, information about personnel personal rights and information within the framework of "confidentiality agreements" concluded with third parties. Cem Ofset Printing Industry Inc. employees; takes care to protect the privacy and private information of customers, employees and other relevant persons and organizations. Protects confidential information regarding the activities of Cem Ofset Printing Industry Inc. and uses this information only for company purposes; shares this information with the relevant persons only within the specified authorities. It is absolutely unacceptable to gain any commercial interest by leaking any confidential information belonging to Cem Ofset Printing Industry Inc. While leaving our company, we have confidential information and documents, projects, regulations, etc. work cannot be taken out.

OUR RESPONSIBILITIES: In addition to our legal responsibilities; to our customers, employees, suppliers and business partners, our competitors, society, humanity and Cem Ofset Printing Industry Inc. We take care to fulfill our responsibilities listed below.

OUR LEGAL RESPONSIBILITIES: We carry out all our activities and transactions at home and abroad. we execute the laws and within the framework of international law, we provide accurate, complete and understandable information to the legal regulatory institutions and organizations in a timely manner. While carrying out all our activities and transactions, all kinds of public institutions and organizations, administrative formations, non-governmental organizations and political parties are at an equal distance without any expectation of benefit. and we fulfill our obligations with this sense of responsibility.

All of our Financial Transactions are carried out in accordance with the law and are controlled and supervised by the Sworn-in Certified Public Accountant service.

OUR RESPONSIBILITIES TO 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 correct way. We deliver our services on time and under the conditions we promised; We approach our customers within the framework of the rules of respect, honor, justice, equality and courtesy. We immediately report quality, safety and rule violations that may have a negative impact on the company or its suppliers’ business to the senior management. The senior management evaluates and notifies the customer as soon as possible.

OUR RESPONSIBILITIES TO EMPLOYEES: We ensure that employees’ personal rights are fully and correctly used. 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, support them in volunteering for appropriate social and social activities with the awareness of social responsibility, and observe the balance between business life and private life.

OUR RESPONSIBILITIES TO OUR PARTNERS: By giving priority to the continuity of Cem Ofset Printing Industry Inc. 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, and we manage our company’s resources and assets, as well as our working time, with an awareness of efficiency and savings. We take care to increase our competitiveness and invest in areas that have growth potential and will provide the highest return on the connected resource. We provide timely, accurate, complete and understandable information about our financial statements, strategies, investments and risk profile.

OUR RESPONSIBILITIES TO OUR SUPPLIERS / BUSINESS PARTNERS: We act fairly and respectfully as expected from a good customer, and we take the necessary 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 TO OUR COMPETITORS: We compete effectively only in legal and ethical fields, avoiding unfair competition. We support efforts to ensure the targeted competitive structure within the society.

OUR RESPONSIBILITIES TO 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. With the awareness of being a good citizen, it acts sensitively as a pioneer in social issues; We try to take a role in non-governmental organizations, public interest services, and appropriate activities on these issues. We are sensitive to the traditions and cultures of Turkey and the countries where we carry out international projects. Bribe or excessive price gift etc. We do not provide or accept products and services.

CONFLICT OF INTEREST: Cem Ofset Printing Industry Inc. employees stay away from conflicts of interest. Taking advantage of our current mission; We do not derive personal benefits from people and organizations with whom we have business relations, personally, through our family or relatives. Cem Ofset Printing Industry Inc. We do not engage in any business activity based on additional financial interests. Cem Ofset Printing Industry Inc. We avoid using our name and power, our identity, for personal benefit.

Cem Ofset Printing Industry Inc. It is essential that employees stay away from situations that may create a conflict of interest. It is among the most important responsibilities of all employees that the resources, name, identity and power of Cem Ofset Printing Industry Inc. are not used for personal benefit, and to avoid situations that may adversely affect the name and image of the institution. The following principles of practice determine the situations of conflict of interest that Company employees may encounter in their private lives while performing their duties or due to their business relationships, and the principles to be applied in such cases.

In the event of a potential conflict of interest, we apply these methods when we believe that the interests of interested parties can be safely protected through legal and ethical methods. When in doubt, we consult our manager and the Human Resources Department.

Application basics : All Company employees are required to fully comply with the situations listed below as activities that may create a conflict of interest, and the principles set forth below. 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 reciprocal benefits with their family members, friends or other third parties in any way. For example, an employee with purchasing authority should avoid doing business with a supplier where a family member works. Exceptional cases are subject to the knowledge and approval of the Chairman of the Company’s Board of Directors. Employees cannot gain any commercial interest by leaking any information belonging to the companies from the inside, or cause others to gain benefits. Cem Ofset Printing Industry Inc. Group employees; They can work in non-profit organizations and universities in social responsibility and charitable roles with the written approval of the management, provided that they do not disrupt their duties within the company. Employees of Cem Ofset Printing Industry Inc. can be active in any political party, individually and voluntarily. Managers cannot ask their employees to do political work or join a party. It is possible for the employees to take part in any political party with the following conditions and the written approval of the management; Employees taking part in any political activity should not create a conflict of interest with their duties, practices and approaches in the company. Employees cannot engage in any political activities during working hours and cannot take the time of their colleagues regarding these activities. Employees cannot change their company name, position, title in the company during their political activities. and cannot use company resources. Employees may make personal financial or moral aid and/or donations to third parties outside the company, and may take part in charitable organizations.

ABUSE OF DUTY: It is unacceptable for employees to harm Cem Ofset Printing Industry Inc. Employees cannot directly or indirectly derive personal gain from the company’s purchasing and sales activities and all transactions and contracts to which it is a party. Employees may not engage in acts and behaviors contrary to morality, law and company discipline.

USE OF RESOURCES: In the use of resources on behalf of the company, the interests of the company are taken into account. Company assets, facilities and personnel cannot be used outside the company, under any name and for the benefit of whoever, 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. Company employees use their time well during business hours and do not spare time for their private work during business hours. Managers cannot assign employees for their personal work. It is essential that special visitors are not accepted during working hours. Employees are required to complete the negotiations for compulsory visitors in a reasonable time in connection with the subject of the visit and in a way that does not hinder the workflow.

RELATIONS WITH OTHER PERSONS AND / OR INSTITUTIONS WITH WHICH THE COMPANY MADE A COMMERCIAL RELATIONSHIP: Private business relations cannot be entered into with the company’s customers, subcontractors or suppliers and other persons and/or organizations with which the company has a commercial relationship, personal borrowing money and/or goods/services cannot be taken, and the company’s commercial relations are not allowed. Borrowing money and/or goods/services cannot be given to other persons and/or organizations with whom it has a relationship. The following matters are taken into account in relations with customers; Even in favor of the customer, a transaction cannot be made without the knowledge of the customer, and even if it is in favor of the company, the customer’s weaknesses cannot be exploited, and no profit motive can be sought by giving incomplete or incorrect information to the customer. Company personnel may not request gifts from other persons and/or organizations with whom the company has commercial relations, and may not imply; No gifts, money, checks, property, free vacations, special discounts, etc. cannot accept. Personal aid and donations cannot be accepted from any person or organization that has a business relationship with the Company. The Policy of Accepting and Giving Gifts is applied in relation to the subject.

REPRESENTING THE COMPANY: All kinds of fees that will accrue in accordance with the duties performed in all kinds of associations, employers’ unions and similar non-governmental organizations are donated to the relevant institution or the channels indicated by the relevant institution. Payments made by third parties to a company employee in return for seminar speaker fee or a similar service are similarly donated to the relevant institution or channels directed by the institution. These people, other than money, are given as a memory of the day and have symbolic value, such as awards, plaques, etc. they can get gifts. Cem Ofset Printing Industry Inc. It is essential that its employees do not accept gifts or benefits that may affect their impartiality, decisions and behaviors, and that they do not attempt to provide gifts and benefits to third parties that may have such effects. The principles of practice defined below regulate the exchange of gifts with third parties and organizations that the employees of the company have business relations with and determine the principles to be applied in this regard.

Application basic : Company employees are prohibited from receiving all kinds of benefits and gifts that may or may not affect their impartiality, performance, and decision-making while performing their duties, whether they have economic value or not.

Company employees; They may receive and/or give gifts with the above-mentioned features or accept to be subject to a special application, provided that they are compatible with the corporate business objectives, in compliance with the current legislation, and that learning of the gift by third parties will not put the company in a difficult position.

Company employees can give and receive entertainment, treats and meals at acceptable standards in the business world, subject to the approval of the Board of Directors. In seminars and similar organizations attended on behalf of the company, awards, plaques, etc., which have symbolic value and as a memory of the day, other than money. gifts can be received.

It is forbidden to receive gifts or benefits that are implicitly or explicitly tied to a reward.

Receiving, giving or offering bribes and/or kickbacks is unacceptable under any circumstances.

It is forbidden for company employees to accept unrequited or borrowed money from subcontractors, suppliers, consultants, competitors or customers, and to cover travel expenses, event expenses and similar payments.

The company’s senior management approves the gifts and promotional materials to be given by the company to the customers and other third parties with whom they have business relations. No separate authorization is required for the distribution of approved gifts and promotional materials.

Provided that it complies with the conditions listed above, the company may accept suitable products and services as gifts, and products or services that comply with the buyer’s culture and ethical values ​​may be given as gifts, with the knowledge and approval of its senior management.

In exceptional cases where local cultural values ​​require reciprocal gifts exceeding the values ​​specified in the company policy, these gifts can only be accepted on behalf of the company and with the approval of the company’s senior management. In any case, the exchange of gifts should be made in accordance with the local culture.

CONFIDENTIAL INFORMATION PROTECTION POLICY: It is the joint responsibility of all our companies and employees to use information effectively, to share it correctly and to ensure the confidentiality, integrity and accessibility of information in this process. It is important that the management systems established for the management and confidentiality of information and the processes implemented in our companies are in harmony with each other in order to obtain the highest level of benefit. The following application principles; It defines confidential information for Cem Ofset Printing Industry Inc. and regulates the principles that employees must comply with regarding confidential information.

Application basics : Confidential Information, including but not limited to, trademarks etc. of Cem Ofset Printing Industry Inc. intellectual property, database, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and partners, including all kinds of innovations, written, found, developed, made or implemented by the staff information, financial information, personnel information, customer lists, product designs, know-how, specifications, identity of potential and real customers, information about suppliers, etc. includes any 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 disclosure is required in accordance with Official Authorities and Legislation.

This information cannot be changed, copied or destroyed. Necessary measures are taken to ensure that information is carefully kept, stored and not disclosed. Changes on the information are recorded 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 information officer or 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.

Company confidential information is not spoken in dining halls, cafeterias, elevators and similar public places.

Company personnel know the degree of confidentiality of the information they obtain due to their duties and act in accordance with this confidentiality. When there is hesitation in terms of confidentiality, a higher confidentiality class is acted upon and the relevant manager’s opinion is sought when necessary.

If information is shared with third parties and/or organizations for the benefit of the company, a confidentiality agreement is first signed or a written confidentiality commitment is obtained from the other party in order to ensure that the responsibilities of these individuals and organizations regarding the security and protection of the shared information are understood.

Unfounded statements and/or gossip about persons or institutions cannot be made.

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

POLICY ON CREATING AND MAINTAINING A FAIR WORKING ENVIRONMENT: Cem Ofset Printing Industry Inc. considers the establishment and maintenance of a fair working environment for its employees as one of its top priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment that is compatible with all relevant laws and regulations. The following principles of practice determine the basic principles regarding the establishment and maintenance of a fair working environment at Cem Ofset Printing Industry Inc.

Application basics : Company practices comply 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 Printing Industry Inc. human resources policies and practices; recruitment, promotion-transfer-rotation, remuneration, rewarding, social benefits etc. ensures that all other practices are fair.

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

A positive and harmonious working environment that supports cooperation is created in the company, and conflict environments are prevented, enabling people with different beliefs, thoughts and views to work in harmony.

The private life and personal spaces of the employees are respected.

Communications between persons cannot be violated by non-parties.

Even if it is recorded in accordance with the law, it is forbidden to unlawfully give/disseminate/capture personal data to others.

Personal information of the personnel arising from the nature of the business relationship and that may be required in the continuation of the workplaces is not used for purposes other than their purposes and is not shared with third parties without the consent of the persons.

The private and family life of all employees is respected.

In addition to all kinds of immunities of the employees, physical, sexual and emotional immunities are also observed. Violating the immunity of employees in any way through physical, sexual and/or emotional harassment in the workplace or any place where they are due to work is against the law and ethical rules, and this crime is not tolerated by the company in any way. The purpose of this application is to protect the employees physically, sexually and emotionally. To enable them to work in a business environment where their personal identity is protected.

Violation of a person’s bodily immunity with sexual behavior and/or sexual harassment without physical contact is defined as sexual harassment. According to this; It is forbidden to exhibit any behavior that can be considered within this definition. In addition, those who make a complaint or report about any harassment or who act negatively against those who assist during the investigation are not tolerated in the same way.

No employee can demand privileged practices, show any privileges to anyone, or be subjected to a special practice due to a different gender, religion, language or race. It is unacceptable to make concessions by making use of differences such as gender, religion, language, race.

It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.

RESPONSIBILITIES OF MANAGERS: Managers of Cem Ofset Printing Industry Inc. have additional responsibilities beyond the responsibilities defined for employees. Accordingly, managers; To ensure the establishment and maintenance of a corporate culture and working environment that supports the ethical rules, to be an example for the implementation of the ethical rules, to train the employees on the ethical rules, to support the employees in submitting their questions, complaints and notifications about the ethical rules, to guide them on what to do when they are consulted, It is responsible for taking into account and communicating it to the Ethics Committee as soon as possible, ensuring that the business processes under its responsibility are structured in a way that minimizes the risks related to ethical issues, and applying 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 Code of Business Ethics and the creation of a culture in which it is supported. The Code of Business Ethics and all related policies are announced to the employees of the company by the Human Resources Department, with the approval of the Chairman of the Board of Directors.

Human Resources, with the cooperation of the Senior Management;

1. To inform the employees about the rules, to provide trainings in certain periods in order to ensure the clarity of the policy and rules, and to ensure the continuous communication of this issue with the employees,

2. To ensure that those who are employed in the company read the ethical rules, are informed about this issue and sign the relevant documents,

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

4. To ensure the occupational safety of the employees who make the notification,

5. To ensure the complaints and notifications are investigated in a timely, fair, consistent and sensitive manner and decisively taking the necessary actions as a result of violations,

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

7. To evaluate the risks that may occur and, if necessary, to revise the relevant policies are responsible for providing.

ANALYSIS OF NON-COMPLIANCE WITH THE CODE OF ETHICS: Those who violate the Code of Business Ethics or Cem Ofset Printing Industry Inc. Disciplinary sanctions will also be applied to those who approve or direct the inappropriate behavior and actions that cause breaking the rules, or who have knowledge of these issues and do not make the necessary notification properly.


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