Code of Business Conduct

1. Basic Principles and Core Values

Mitaş Industry, together with its employees, aims to provide products and services in line with the international quality and standards, as well as sustainable and profitable growth by providing high customer satisfaction.

For this purpose, Mitaş intends to become a symbol of reliability, continuity, and prestige for its country, customers, shareholders, representatives/distributors and vendors, suppliers, partners, and employees.

Mitaş Industry’s top priority is to create value for our customers and to fulfill their expectations with quality and stability.

The principal goal of Mitaş Industry is to carry out its activities as per the binding regulations; to be the best at the quality, service, and supply management as well as at the relationships with the representatives/distributors/ vendors, and suppliers; to create sustainable shareholder value, act in line with the ethics, maintain customer faith and develop our company.

To achieve this goal, it is our fundamental policy to shoulder the leadership in our field of activities and become the leading company in the market.

The quality of our products and services are initiated with our employees’ qualifications. Attracting and employing the best workforce and the very best personnel, to have the maximum benefit of our people’s skills, power, and creativity, increasing their productivity, creating opportunities for them to develop and a working environment of co-operation and unity have been our way to maintain Mitaş’s continuity for generations.

It is our fundamental principle to create sources from the activities, and make sure the sources are utilized wisely and not wasted to ensure the continuity of the activities, realize investments, create values for the shareholders, help develop our employees and the society both economically and socially.

Mitaş Industry acts in line with the ethics in its all business processes and relationships together with its employees.

Full-time employees of Mitaş Industry cannot work at another company during their contract with Mitaş, nor they can self-employ directly or indirectly.

The works carried out by our employees for the third parties, concerning the benefit of Mitas Industry, under the approval of the President or the relevant Vice President, shall not be considered a violation of the aforesaid policy. In case of doubt, Human Recourses Directorship is consulted with.

Employees can take part in activities for the public weal as long as they fulfill their responsibilities to Mitaş, and these activities shall not be considered a violation of the aforesaid policy provided that the employees get written consent from their department and Human Resources Directorate.

At Mitaş Industry, respecting human rights is our priority.

2. Compliance with The Laws and Company Procedures

Mitaş Industry, during its all business activities, makes a point of acting in line with the company policy and procedures, the ethics, international treaties in which the Turkish Republic is engaged.

Mitaş Industry sticks to honesty, accountability, and transparency in its relationships with officials; gives importance to in-time submission of information, documents, and records required for inspection and controls.

The employees must be aware of and follow Mitaş Industry’s policy, procedures and instructions with regard to their responsibilities.

The employees are obliged to act with caution and be attentive in the international business relationships in order not to cause any act against policies and regulations of the Turkish Republic, company procedures, and laws of other countries, and international laws.

The employees are responsible for reporting any acts against laws and rules, company procedures, and working policies to the Human Resources Directorate. The company shall keep the informing personnel’s identity confidential.

3. Prevention of Discrimination and Harassment

Mitaş Industry guarantees that in the selection and placement processes it will provide equal rights to its employees regardless of their language, race, color, gender, belief, religion, communion, political opinion, age, or disability.

Mitaş Industry will not tolerate any mobbings at the place of business.

Those who violate this policy will not be tolerated and any employees harassing another employee or a third party will be punished. This process is carried out as per The Discipline Directive.

Mitaş Industry expresses its respect for the following four principles even if it has not approved “Fundamental Principles and Rights at ILO Working Life” and relevant agreements:

  • Freedom to establish a union and accepting collective bargaining rights,
  • Eliminating all types of human trafficking, slavery, work by force,
  • Preventing child labor,
  • Eliminating discrimination during a work contract.

4. Environmental Protection

For Turkey and the World, it is our duty to act as conscious of the protection of the environment and expand this consciousness.

Mitaş Industry supports preventive acts against environmental threats, takes initiatives to develop environment-friendly technologies, and spread responsibility for a more effective environment.

Mitaş Industry aims to protect and make the best of natural sources, keep the environmental effects as a result of its products from the design to the expiry date under control, minimize and recycle the wastes.

We carry out works to support recycling and re-usage activities for our employees and increase awareness on these issues.

Cooperating internationally, Mitaş Industry supports transparency policies to reduce greenhouse gases.

Mitaş Industry prefers in its selection for the services and products to work with suppliers that have more sensitive activity/manufacturing systems to the environment and the society.

5. Occupational Health and Safety

Mitaş Industry aims to provide occupational health and safety entirely in the working areas.

All employees act in line with the relative rules and directives and take necessary precautions.

The employees cannot have any illegal or dangerous objects or materials to the workplace and workers.

The employees cannot have any drugs, addictives, materials that deteriorate physical and mental activities present at the workplace and cannot work under the effect of such things.

The employees comply with the requirements described in Emergency Action Plan to protect themselves, their co-workers, information, and information systems. In case of terror, natural disasters, etc., the Emergency Crisis Desk acts according to the Emergency Action Plan.

6. Intellectual and Industrial Property Rights

Mitaş Industry avoids any acts leading to unfair rivalry, or patent, beneficial model, industrial design, copyrights, trademark, and similar intellectual and industrial property rights. The employees shall take all precautions to comply with these issues and report any nonconformity to the Human Resources Directorate.

Mitaş Industry makes a point to guarantee its trademarks, qualified inventions, and works by establishing registration, patent, beneficial model, industrial design, and similar intellectual and industrial property rights.

Within this framework, the employees document their inventions as per Mitaş Industry’s procedures and report to the management. Such inventions and information cannot be shared with any third parties without the written consent of the Mitaş Industry.

The employees, when it is necessary to share confidential information about intellectual and industrial property rights of Mitaş Industry, to protect these rights take required measures within the procedures of Mitaş Industry.

The employees meet their needs via Information Technologies Department as per Mitaş Industry’s procedures when they need software for the company computers. These computers are used for work purposes only. No software can be uploaded on the company computers without the knowledge or approval of the Information Technologies Department.

The employees cannot disclose confidential information or documents belonging to their previous employers to Mitaş Industry and other workers and cannot ask their co-workers to disclose such information or documents of their ex-employers.

The employees cannot copy and use creations within the scope of copyrights without the permission of the owner.

Employees are under the obligation to take the required care and attention to avoid illegal use, copy or reproduction of third party intellectual and industrial property that can result in financial and criminal penalties to committers of these acts, Mitaş Industry and its executives. This process is carried out as per The Discipline Directive.

7. Information Management and Confidential Information

Information Security is amongst Mitas Industry’s priorities. The employees are obliged to act in line with the Integrated Management System Policy.

The employees preserve any commercial, financial, technical, and legal information that they obtain within their works, and do not disclose these to other persons and institutions that have no relationship with our businesses, and when it is necessary to disclose such information to the third parties under the business, they only share the necessary portion and take precautions to protect it.

The employees are obliged to fulfill all requirements concerning the protection of privacy outlined in the Labor contract, and if available, Confidentiality Agreement. They are also obliged to act in line as per confidentiality obligations after they quit their jobs.

It is forbidden to talk publicly about confidential information of the company. Talking in social media and similar platforms about the company’s confidential projects, incomes, business meetings, products, prototypes, designs, processes, and similar commercial secrets and information that are not made public is prohibited. Especially, taking pictures of products and manufacturing fields at a project level, and sending these pictures and any other available photos with a third party within or outside the company is not allowed.

All types of documents (correspondences, notes, computer files, and electronic mails, etc.) created by the employees for working purposes belong to Mitaş Industry. Such documents shall be preserved and demolished according to Mitaş Industry’s procedures.

The employees cannot use any misleading, wrong, exaggerated, unreasonable assumptions, vague or improper information or statement in any documents they use or create.

The employees cannot use any confidential information for their own or other person and institution's benefit.

The passwords, user names, and similar defining information used to access company information are kept in privacy and not disclosed to unauthorized persons.

It is Mitaş Industry’s policy to support investigations conducted by the authorities and provide correct and accurate information.

It is not allowed to bring a camera and take photos of products and manufacturing areas.

8. Social Responsibility

Mitaş Industry, while making contributions to our country’s economy and increasing its competing power worldwide, as per institutional citizenship perceptive also carry out numerous social responsibility projects in the fields of education, health, culture, art, and sports for Turkey to reach its sustainable development targets.

Mitaş Industry with social responsibility awareness encourages its employees to volunteer in social activities.

9. Policy of Contract and Binding Legal Operations of Company

In the case of all business relationships of the Company, it is mandatory to sign a contract outlining the rights and obligations of the parties before the start of said relationship.

Contractual processes are executed by the administrators (“Contract Administrators) per related written rules.

If a contract interests several departments, the Contract Administrator is obliged to report to the Department Managers.

Only the Authorized Persons stated in the Board Directives and those given authority with a special power of attorney can represent Mitaş Industry. No other persons can represent Mitaş Industry, or commit, sign anything, or act on behalf of the Company.

Authorized Persons stated in the Board Directives and those given authority with a special power of attorney will act within the borders of given authorization during the transaction they carry out.

In case of an extension of contracts, tenders and purchasing activities are repeated within a reasonable time before the expiry date of the contracts. If agreed upon an extension, the required extension protocol will be put under signature in line with the Board Directive.

If any non-conformity with the Contract is detected Contract Administrator is responsible for evaluating these and notifying the other party.

10. Competition

In terms of compliance with the “Rivalry Regulation”, Mitaş Industry executes its businesses as per “Zero Risk” policy. Accordingly, all the employees avoid any acts that may pose a risk under the Rivalry Regulation.

Mitaş Industry under no circumstances commits any act, directly or indirectly, to prevent, cease or restrict rivalry in the market of a product or service between its opponents or other companies, or make an agreement or acts creating such effects.

When Mitaş Industry has a sole or joint dominance in a certain market, Mitaş will not breach this dominance solely by making contracts with others.

It is strictly forbidden for the employees of Mitaş Industry to share sensitive information in terms of Rivalry, directly or indirectly, with the workers of opponent companies. Price of the products, price changes, increase in prices, date of price increase, pricing strategy, discounts, profits, bidding price and conditions, production capacity, capacity usage, stock, sales, orders, import&export, sales targets, costs, investment plans, customer lists, representatives’ incentives, and bonuses and other similar information that are not made public and trade secret or in case of sharing with opponents, which may result in rivalry breach, but not limited to these, are defined as “ Rivalry Sensitive Information”.

Events such as union, chamber, etc. entrepreneurship meetings with the employees of opponents may carry high potential risks in terms of Rivalry Regulation breach. Mitas Industry’s employees will not participate in these kinds of meetings in case that agreements, discussions, or negotiations are against the Rivalry Regulation, and if they already have attended such meetings they will immediately leave the meeting and notify the Human Resources Directorate in written.

Mitaş Industry respects its agents and authorized service providers’ right to decide on their own pricing, profit, and discount rates; and avoid any acts or statements preventing the said rights.

Mitaş Industry’s employees duly comply with the directives and procedures defined by the Company, act in line with these within the department, make necessary warnings, in case of a doubt relevant to the Rivalry Regulation, report to and take advice from the Human Resources Directorate.

11. Prohibition of Political Activity

Mitaş Industry cannot take part in supportive activities for political parties, politicians, or nominees, nor can make any donation for the aforesaid. In these issues, Mitaş Industry does not allow campaigns or similar activities within the workplace. Mitaş Industry’s resources (vehicles, computers, e-mails, etc.) cannot be used for political activities.

12. Product Safety and Quality

The safety and quality of the products are Mitaş Industry and its employees’ priority. Within this context, the employees are responsible for ensuring the safety and quality of the products under the standards and procedures of the Company.

Mitaş Industry and its employees aim for continuous enhancement to ensure persistence in the safety and quality of the products. For this, it is a primary goal of Mitaş Industry and its employees to expand the quality culture to the employees, business partners, and suppliers.

13. Relations with Stakeholders

Mitaş Industry adapts it as a policşty to always act professional, kind, and fair in the relationships with its customers, distributors, authorized service providers, suppliers, contractors, and other partners. The employees are obliged to comply with this policy.

The employees cannot act in a way to discredit Mitaş Industry, both at work or in their private life, before the public or other persons or institutions with whom Mitaş has a relationship.

The employees avoid all acts, activities, statements, or behaviors that may be considered damaging, calumnious, humiliating, derogatory, devious, discriminating or unfair rivalry to each other.

It is Mitaş Industry and its workers’ duty to protect our products and support customers after-sales.

Mitaş Industry targets to become a leader in customer satisfaction and loyalty in the sector. In this concept, the employees in all customer relationships act always with respect, helpful and frank, and report all customer requests to the Quality Assurance Department and FAT Unit.

Personal relationships with suppliers and distributors cannot affect the decisions of the employees. The employees can never use their relationships with Mitaş Industry for their own or other third parties' benefit.

14. Anti-Corruption and Situations Regarded as Improper or Illegal

Mitaş Industry acts in line with the “Zero Risk” policy to fight corruption, and the employees are obliged to comply with the directives and procedures by Mitaş Industry.

Mitaş Industry is aware of its responsibilities in Money laundering, financing terrorism, and other crimes.

The employees cannot, directly or indirectly, or via third parties give or offer bribe, present, easing payment to any person or institution whatsoever.

The employees cannot, directly or indirectly, or via third parties take or accept bribes, present, amenities to any person or institution whatsoever.

Mitaş Industry’s employees are obliged to act in line with the ethics outlined in article 15, take necessary precautions, and carry out the inspections for the direct or indirect business and relationships of Mitaş Industry and its partners, distributors, agencies, advisors, and consultants.

The employees fulfill their duties as per working principles and procedures to keep Mitaş Industry’s benefit at a maximum level. The principles to prevent potential interest conflicts that may arise between Mitaş Industry and its business partners or those who may wish to conduct business with Mitaş Industry are as follows:

  • No gifts or promotions can be accepted, except for the gifts or promotions that cost no more than €50 or do not signal any irregularity. Otherwise, they should be returned in a kind manner.
  • No gifts or promotions can be given other than the promotion or amenities that cost more than €100.
  • Discounts or benefits that are not made available in general for a product or service cannot be accepted or applied.
  • Cash, gift cheque, or valuable metals cannot be given or taken as a present.
  • Loans on special conditions that are not applied for everyone cannot be taken from banks and financial institutions.
  • The employees cannot demand or accept support for recreation, education, sport, or entertainment from persons or institutions that have or may have a business relationship. If the employees demand donations from other persons or institutions, it is ensured that those who will make the donations should not be affected by the position of the employees.
  • Authorized persons of Mitaş Industry cannot be invited to recreational, educational, sport or entertainment activities except for the events organized publicly or official assignments by gövermen institıutions.
  • Apart from the ones carried out as per approval by the President or Human Resources Directorate, the employees or their families cannot be given presents on behalf of Mitaş Industry. Supportive activities (social responsibility projects, scholarships, sponsorships, etc.) conducted by Mitaş Industry are exceptions.
  • The employees cannot support any activity, union, person, or institution on behalf of Mitaş Industry or gain advantage unless the Human Resources department issues permission.
  • Having a share or advantage at a company that has or wants to have a business relationship with Mitaş Industry is only possible with the approval of the Mitaş Industry Board of Directors. The employees will immediately inform the Human Resources Directorate of any financial benefit they or their family members have at other companies with a Business relationship with Mştaş Industry.
  • The employees with the title of executive cannot loan money to those who work under themselves or take money from them, or ask them to be a guarantor in monetary transactions.
  • The employees cannot participate without approval by the President or Vice-President in the incentive-likes event such as invitations, domestic or international trips, sports events apart from the conference, reception, advertising activities, seminars, etc. organized publicly by the persons or institutions that have or may have a business relationship with Mitaş Industry.
  • The executives cannot ask employees or subcontractors to do a task other than their duties and responsibilities at Mitaş Industry, nor they can request any activity outside of working hours for a fee or free of charge. The employees are required to report any case against the Laws or company procedures and regulations in relation to the Corruption Regulations (defined in the Discipline Directive) to their managers and Human Resources Directorate.

15. Ethical Rules

The employees, to fulfill their duties, act based on continuous development, participation, transparency, objectivity, honesty, protecting Mitaş Industry’s benefits, accountability, predictability, and trust in declarations.

The employees aim to facilitate daily life, enhance product/work quality, increase the satisfaction of the workers, and be result-oriented to fulfill their duties. The executives of Mitaş Industry use their managerial Powers within the institutional discipline and professional standards. They provide the workers with the information relating to the works and transactions and clarify them about the work processes.

The employees cannot apply pressure, insult, or threat while they carry out their duties.

The employees behave in a manner worthy of the trust that their positions require, and within this scope, display the necessary attention for the works. The Company will not tolerate neglecting the duty and wrongdoing.

Conflict of interest refers to all kinds of benefits and similar personal interests which affect the employees or seem to affect the impartial and objective performance of employees' duties, or even if it does not affect them, which are provided to employees, their relatives, friends or people and institutions with whom they are in a relationship. The employees are personally responsible in the event of a conflict of interest and because they may generally be aware of a potential conflict of interest, they act carefully in case of an arisen or potential conflict of interest, or take necessary actions before it arises, or once realized they report to their managers and avoid benefits which are within the conflict of interests.

The employees cannot use or allow others to use Mitaş Industry’s building and vehicles, resources, and goods other than the business purposes of Mitaş. They protect and use wisely these and ensure to keep these available.

The employees avoid waste and extravagance in the use of all kinds of resources that belong to Mitaş Industry. They act effectively, productively, and frugally while using the working hours, goods of Mitaş Industry, resources, workforce, and opportunities.

The Executives take all necessary precautions to ensure the principles of this Working Principles and prevent all types of abuse within their area of responsibilities. These precautions include implementing legal and administrative regulations, executing necessary inspections and controls, carrying out proper activities in training and information exchange, acting carefully in the event of financial and other difficulties that the employees face, and being a good example for the employees.

16. Business Relations of Ex-employees with Mitaş Industry, Its Shareholders and Subsidiaries

Performing sales, contracting, consulting, brokerage, dealership, or similar jobs personally or as a partner or manager in a company by the Ex-workers of Mitaş Industry and its subsidiaries are the cases that cause a conflict of interest and ethical concerns. Thus, to eliminate these doubts, complying with the following articles is the responsibility of all employees.

  • No business relationship can be formed with an ex-employer or a company in which the said person is a partner or executive unless 2 years have passed since the person in question left Mitaş Industry.
  • In the event that any business relationship is to be formed with such persons or companies, the fact that the person is an ex-employer of Mitaş Industry will not be the reason for the concerned business relationship.
  • In such cases, the established purchasing rules of the company will prevail.
  • In such cases, the related Vice-President will be informed of all transactions.
  • Any exemptions to this article will only be possible by the written consent of the President and Human Resources Directorate.

17. Protection of Personal Data and Customer Data

All types of information belonging to a real person who is identified or identifiable are considered Personal Data. In addition to this definition a name, surname, marital status, date of birth, vehicle plate, voice and image records, fingerprint are also personal data. These types of data belonging to the employees and visitors of Mitaş Industry, and employees and partners of Mitaş’s distributors, visitors, suppliers, sub-contractors, authorized service providers, and potential customers are also Personal Data.

Personal Data: cannot receive or saved in Mitaş Industry’ systems except for: (i) The legal necessity with regards to Mitaş Industry, (ii) a contractual relationship with Mitaş Industry, (iii) as per Mitaş Industry’s legitimate interests iv) a documented approval of the relating persons.

Personal Data is qualified as Confidential Information, thus, its access is restricted and controlled. Personal data cannot be stored outside the data storage unit determined and approved by the company. Personal Data cannot be saved on the employee's computer unless approved by Nitaş Industry with an administrative decision.

The employees of Mitaş Industry are obliged to comply with the procedures and directives in relation to obtaining, preserving, accessing, using, transferring to third parties, sharing with foreign countries, making a subject to contracts, erasing, anonymizing Personal Data, and satisfying the owner of Personal Data. In case of a violation of legal regulations, legal and punitive sanctions may be arisen, including imprisonment.

Communication with the available or potential customers for the purpose of marketing, advertising, campaign, survey, research, introduction, or collecting data is not allowed. Before having such communication it should be ensured as per company procedures that the relating approvals are available.

The employees cannot use Personal Data that they have obtained in relation to the activities of Mitaş Industry other than business purposes.

The employees are responsible for notifying the Human Resources Directorate of all cases contrary to the procedures and directives relating to Personal Data.