Anti-Bribery and Anti-Corruption Policy

ANTI-BRIBERY AND CORRUPTION
Purpose and Scope

With the Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as the “policy”); It is aimed to determine the approach and responsibilities of Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) against bribery and corruption, to prevent bribery and corruption in Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) activities, and to protect the integrity and reputation of Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) by providing information and reporting on this issue.

 

Anti-bribery and anti-corruption policy covers all employees, including the Board of Directors of Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm), and individuals and organizations (business partners) outside of Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm), who work in cooperation with Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm), such as suppliers, auditors, consultants, authorized sales agents, corporate customers.

This policy is an integral part of Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm)'s working principles. It has been disclosed to the public, business partners and all Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) employees, and Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) business partners and employees have an obligation to comply with these policy principles.

Definitions

Bribe: It is the provision, offer or promise, demand or acceptance and intermediation of a benefit, directly or indirectly, to himself or to another person to be designated, in order for a person to do, not to do, slow down or accelerate a job related to the performance of his duty.

Corruption It is the misuse of the authority held by duty and position for the purpose of obtaining any kind of benefit, directly or indirectly.

Corruption and bribery can also take place in different forms such as gifts, donations, commissions, entertainment, social benefits other than cash payment.

Gift: Generally, it is the product or products given by people, guests, customers, suppliers or as a commercial courtesy to these people and customers.

Ethics Committee: Members of the Executive Board are members of the ethics committee. According to the content of the subject, managers responsible for the relevant function may be invited to the board.

Our Policies and Procedures

The business relationship with 3rd parties who want to do business or do business with Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) through bribery or corruption should not be continued. In this context, it is stated in the contract provisions that come into effect after the date of this Policy that the relations will be terminated unilaterally for a just cause as a result of activities contrary to this policy. These provisions also apply in case of policy violations. In terms of contracts concluded before the date of this policy, relevant business partners are informed about the policy content.

 

All kinds of gifts given or offered to third parties by Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) are given openly and unconditionally in good faith. The same principles apply to gifts given or offered by third parties. In addition, gifts that lack symbolic value and have high material value should not be accepted. Even if it is accepted in accordance with this, the acceptance of gifts should not be frequent. In case of having to accept gifts frequently, notification should be made to the senior manager/Executive Board member and/or Group Human Resources and Training Directorate. These reports are evaluated and forwarded to the ethics committee if necessary.

 

No gifts should be accepted or offered other than those given in accordance with legal and commercial traditions, customs or souvenirs / promotional materials. As long as the commercial traditions of that country do not conflict with our basic ethical values, our internationally operating company can be taken into account in its activities related to individuals or organizations from outside our country.

 

Donations to be made by Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) are made publicly and after the approval of the board of directors. Employees of our company are free to make individual donations regardless of their jobs. However, the donations they make independently of the company by raising money among themselves must also comply with the business ethics rules and the anti-bribery and anti-corruption policy.

In cases that are claimed to be against the policy, necessary sanctions or sanctions are applied as a result of the examination and investigation by the ethics committee.

Authority and responsibility

Announcing, implementing, updating and supervising the implementation of the policy are under the authority, duty and responsibility of the Executive Board. In this context, management;

By announcing this policy to the companies, business partners and all stakeholders, from which goods and services are bought and sold,

To ensure that the employees are informed about the subject and their assurances in case they make a report,

Establishing an ethics committee to monitor compliance with the policy, auditing that this committee works impartially in accordance with the law and policy,

It is responsible for the implementation of the decisions of the ethics committee and the operation of the enforcement mechanisms.

In terms of the implementation of the policy, all Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) employees are also

By operating in accordance with the determined policies and relevant legal regulations,

Notifying the ethics committee when faced with an activity or behavior contrary to the policy,

is responsible.

Goods and Services Purchased, Sold Companies and Business Partners

It is obligatory for the companies and our business partners to comply with the principles of this policy and the relevant legal regulations. Works with individuals and organizations that do not comply with these principles or the relevant legal regulations are terminated.

In this context, during the selection of business partners, the compliance of the persons and institutions with the policy principles is also taken into account by the senior management. Even if they meet all other criteria, it is not possible to work with individuals and organizations about whom negative intelligence regarding bribery and corruption is obtained. Before entering into a business relationship, the necessary intelligence research should be done, the results of the research should be evaluated or reference research should be done.

In the contracts to be made after the date of this Policy with the persons and organizations to be worked with as a result of the research and evaluation;

Ensuring full compliance with the principles specified in the policy and other relevant regulations,

Employees assimilate these principles and act accordingly,

Ensuring that its employees receive training on the Policy periodically,

Requirements are given for regular reminders to its employees regarding their reporting obligations and the Ethics Line, and encouraging them to notify them if they encounter such situations. In case of non-compliance or a situation contrary to the policy, the provisions regarding the unilateral termination of the works and the contracts in force with just cause are also included.

In terms of contracts concluded before the date of this policy, companies and/or employees who are party to the contract are informed about this Policy.

Keeping Records

In order to implement the policy, the accounting and recording system must work in accordance with legal regulations. According to this

Recording all kinds of accounts, invoices and documents related to relations with third parties (customers, suppliers, etc.) in a complete, precise and accurate manner and keeping them in accordance with the relevant legal statute of limitations,

Not to falsify the accounting or similar commercial records of any transaction and not to deviate the facts,

The notifications made to the ethics committee regarding the fight against bribery and corruption and the actions of the ethics committee should be fully recorded and preserved.

Education

The anti-bribery and anti-corruption policy has been announced to all Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) employees. It is kept up-to-date and published open to the access of all employees.

Raising awareness of our employees against bribery and corruption is essential for the implementation of our policy in the fight against them. In this direction, training programs are organized especially to explain that our employees will be safe after their notification.

Notice of Policy Violations

In the fight against bribery and corruption, notifications of our employees and all our business partners are of great importance. Our employees and business partners should report to the Ethics Committee as soon as possible their opinions and suspicions that there is a violation of this policy.

Notifications must be sent with the form sample content in the ethical violation notification link.

Employees are reminded periodically on how to make notifications. Persons and organizations or business partners from whom goods and services are purchased or sold are reminded in this regard and they are provided to make a notification. This issue is guaranteed by the contracts made.

Ayas İsos Turizm Seyahat Automotive Trade Limited Company (Ayas Turizm) encourages all its employees and business partners to express their opinions and doubts in good faith. The notifications made to the Ethics Committee are kept confidential and no reporter can be subjected to pressure or punishment, nor can the job description or location of the employee be changed due to the notification made to the Ethics Committee. Subjecting the whistleblower to such pressure or punishment is considered a violation of the rules of business ethics and is evaluated by the Ethics Committee and appropriate sanctions are applied.