ETHICS POLICY

INTEGRITY

Integrity is our priority in all of our business processes and relationships.

CONFIDENTIALITY

As Asistal employees, we are committed to ensure that confidential and/or proprietary information of our customers, employees, and other business partners is protected and such confidential and/or proprietary information is only used within the defined authorization policies and for appropriate purposes.

OUR LEGAL RESPONSIBILITIES

Our main principle is to ensure that our financial and commercial records are always accurate, complete, and understandable. We carry out all of our domestic and international operations and activities related to manufacturing and sales of products in accordance with the laws, codes, and regulations of the Republic of Turkey as well as international standards and rules of law.

We observe an equal distance policy towards all public institutions, administrative structures, civil society organizations, and political parties without any expectation of any advantage when carrying our operations and activities and we fulfill our obligations with a sense of responsibility.

OUR RESPONSIBILITIES TO OUR EMPLOYEES

All employees of Asistal Aluminum work of their own free will. We treat all of our employees equally in accordance with our code of ethics and respect their individual rights and freedoms.

We ensure that the personal rights of our employees are fully and freely exercised.

Asistal Aluminum acts in line with the laws of the Republic of Turkey with regard to child labor. We do not, in any way, permit or support the employment of children or minors.

We treat our employees with integrity and fairness and guarantee a safe and healthy working environment where discrimination is not tolerated.

OUR RESPONSIBILITIES TO OUR CUSTOMERS

We work with a proactive approach with a focus on customer satisfaction and respond to our customers’ needs and demands in the shortest time and in the most accurate manner. We adopt the principles of respect, integrity, fairness, and equality when dealing with our customers.

OUR RESPONSIBILITIES TO OUR SUPPLIERS/BUSINESS PARTNERS

We treat all of our suppliers and business partners fairly and respectfully and take due care to meet our obligations on time. We carry out training/auditing activities with a focus on development / improvement.

OUR RESPONSIBILITIES TO OUR COMPETITORS

We only compete within legal and ethical boundaries and avoid unfair competition. We contribute to all efforts to ensure an ethical competitive environment.

CORRUPTION AND BRIBERY

Scope

Asistal employees refrain from soliciting or accepting gifts, advantages, benefits, or hospitality which may affect their impartiality, decision-making, and behavior from persons and/or organizations with whom the company has a business relationship, for themselves or others. The same applies to third party persons and organizations as this may be perceived as an attempt to influence the impartiality, decision-making, and behavior of third party persons or organizations.

Definitions

Corruption refers to the abuse of an authority position, either directly or indirectly, for the purpose of pecuniary or non-pecuniary gain. An act of corruption may result not only in the legal or criminal sanctions against the perpetrators, but in the event that they have failed to fulfill their supervision duties at the time of the act, against their managers and the organization which they represent. Bribery is one of the most common examples of corruption.

Bribery is the payment or the provision of an interest to influence decisions or actions of a person, either directly or indirectly, and have them do or refrain from doing a job in a way that is not in line with the requirements of the task. This may happen in many different ways such as making a payment in cash or in kind, making donations, giving gifts that have more than symbolic values, or making an offer that will provide personal benefit. Bribery is a crime as per the Turkish Penal Code, which also sets out the sanctions and penalties which may be imposed on employees of public joint stock companies who commit acts considered as bribery.

Facilitation Payment is an in cash or in kind payment made to public officials to achieve the rapid processing or secure the outcome of justifiable and routine services (legal permits, visa applications, etc) provided by public institutions. It is in no way acceptable for individuals and organizations covered by this policy to make such payments. Asistal employees cannot be held responsible for any disruption or delay in their business processes due to failure to make facilitation payments.

Legal Environment

The Organisation for Economic Co-operation and Development (OECD), of which Turkey is a member, signed the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions in 1999 and emphasized the importance of preventing any bribery that may occur during commercial transactions. All members countries of the Organisation for Economic Co-operation and Development have defined benefits provided or offered to public officials, either national or international, as a crime. Similar conventions highlighting the sensitivity of this issue have also been signed in other international platforms such as the United Nations and the Council of Europe. The Republic of Turkey has agreed to be a party to these agreements as well and implements regulations brought about by these conventions.

Purchasing and Sales Processes

Asistal carries out its purchasing operations with transparent business processes and based on objective criteria. In purchasing goods and services, it is essential for Asistal to work with suppliers who provide added value by supplying goods and services directly, do the billing themselves, and act in a financially and legally responsible manner. Asistal may work with intermediaries in cases where the supplier requires and with the approval of the Board of Directors. In such mandatory and exceptional cases, it is essential that the negotiations with the intermediary be conducted by contacting the original supplier company. In addition to purchasing department employees, a second person from the company is required to be involved in all negotiations with suppliers during the purchasing process. All other details of Asistal’s purchasing practices are specified in the Purchasing Process.

Sales and Marketing Processes

Asistal works directly with its customers or through an intermediary approved by the Board of Directors. All direct contacts with customers are established either through the corporate authorization provided by the customer or through an intermediary with official representation authority.

Third Parties Acting on Behalf of Asistal

Third parties acting on behalf of Asistal may not, in any way, receive or provide any benefit for the purpose of inappropriately influencing a commercial decision. If Asistal becomes aware of a non-compliance with company policies and legislative regulations, the issue is handled together with the Board of Directors, Administrative Affairs Unit, and Legal Advisor and the sanctions defined in company policies are implemented based on the decision made.

Recruitment Process

In addition to the existing Human Resources Procedures, Asistal performs extensive background scans and reference checks with consent of the relevant person during the recruitment of employees for key positions.

Accuracy of Records

Asistal is committed to recording and maintaining all accounts, invoices, and documents in a complete, precise, transparent, and accurate manner in accordance with applicable legislative regulations. Asistal does not falsify accounting or other business records related to any transaction and documents related to these records. The accuracy of the records is ensured through Asistal Aluminum internal control environment, control activities, and reporting and monitoring practices. The financial statements of Asistal Aluminum are regularly audited by independent audit firms.

Training

Asistal develops and implements face-to-face trainings and programs to increase the awareness and competence level of Asistal employees on Ethical Rules and Anti-corruption with the support of their respective units.

Confidentiality and Protection of Trade Secrets

Asistal employees acknowledge and undertake they shall protect the confidentiality of the information which is provided to them by Asistal for the performance of their duty or they may learn by being at the workplace and provide Asistal with a competitive advantage, shall not use such information to achieve an unfair competitive advantage after leaving the job, and shall not disclose such information to third parties without written approval of Asistal. Asistal employees shall not disclose any confidential information referred to as “Trade Secre” such as any software, technology, know-how, system, application, and method developed by Asistal or any idea, application, design, model, work, and invention which is not yet known or used in the industry without written approval of Asistal.

Disclosure of Acts of Bribery and Corruption

In order to protect the reputation of our company, it is the responsibility of everyone mentioned above to report any act that violates anti-bribery and anti-corruption rules. Failing to report or ignoring acts of bribery and corruption which the person becomes aware of to the relevant authorities shall also be considered a violation of anti-bribery and anti-corruption rules.

Our communication channel to report suspected rule violations or situations which may damage our reputation and credibility is asistal@asistal.com.

Violation of Anti-bribery and Anti-corruption Rules and Consequences

All employees and all business partners specified in this policy are required to know all the rules and conduct their business in accordance with these rules and applicable legislation related to combating bribery and corruption. In the event that any of these rules is violated, criminal sanctions shall be imposed in line with the nature of the violation.

Employees or business partners shall not not subjected to any negative reprimands for refusing to participate in an act of bribery or corruption or for reporting an act of bribery or corruption. The communication channel specified in this policy needs to be used in such cases.

DISCRIMINATION

Asistal offers equal opportunities for all and does not discriminate persons based on age, race, religious beliefs, skin color, gender, language, nationality, marital status, sexual orientation, seniority, political beliefs, military status, actual or perceived disability, or other legally protected traits.

This policy applies to all terms and conditions of employment such as recruitment, placement, promotion, termination of employment, dismissal, recall, transfer, leave, pay, and training.

ENVIRONMENTAL MANAGEMENT

Asistal always acts with an awareness of social benefit and environmental protection. Asistal aims to implement high standards regarding environment.

OHS MANAGEMENT

Asistal considers the health and safety of its employees, suppliers, and customers in all of its operations, complies with legal requirements related to Occupational Health and Safety, carries out necessary infrastructure works to prevent occupational accidents and diseases, and ensures continuity.

Muzaffer Engin ÖZTEL
Chairman of The Board of Directors