Anti Bribery and Anti Corruption Policy

Anti Bribery and Anti Corruption Policy
ESG

1. PURPOSE AND SCOPE

This policy covers all employees, board members, representatives, service providers, and business partners of Türkiye Hayat Emeklilik A.Ş. Our aim is to ensure that all of our activities are conducted in compliance with ethical standards, as well as national and international anti-corruption laws.

2. DEFINITIONS

Corruption: Any illegal act performed with the aim of benefiting oneself or others by abusing one’s position.

Bribery: When a person provides or offers benefits, either directly or indirectly, to another person in exchange for favoring the performance of their duties. These benefits can take various forms, including cash, valuable gifts, travel, donations, or debt forgiveness.

Facilitating Payments: Small-scale payments made to expedite an official process or obtain a service.

Conflict of Interest: A situation where an employee or related party acts in a way that their personal interests could harm the company’s interests.

 

3. FUNDAMENTAL PRINCIPLES

As Türkiye Hayat Emeklilik, we conduct all of our activities in line with the following principles:

Gift and Hospitality Policy: No employee or officer of Türkiye Hayat Emeklilik A.Ş. can accept or offer unethical or illegal gifts to influence any decision related to the continuation of Türkiye Hayat Emeklilik A.Ş.’s activities or for its benefit. Gifts must be within the boundaries of courtesy and reasonable limits.

Donations and Sponsorships: Donations and sponsorships are made only in alignment with the values of Türkiye Hayat Emeklilik A.Ş. and in a transparent manner. No donation or sponsorship can be made for the purpose of bribery or obtaining illegal gains. Donations are made within the limits set by the General Assembly, as specified in the relevant legislation and the Capital Markets Board’s rules under the corporate social responsibility projects. Donations are added to the distributable profit base.

Political Donation Prohibition: Türkiye Hayat Emeklilik A.Ş. does not make any donations or provide support to any political party, political candidates, or political organizations.

Relations with Business Partners: Türkiye Hayat Emeklilik A.Ş. expects its representatives, service providers, and business partners to act in accordance with this policy. No business relationship is established with individuals or entities linked to bribery or corruption.

Prohibition of Facilitation Payments: No payments are made to public officials or private sector employees to expedite official procedures or gain an advantage.

Prevention of Conflicts of Interest: Employees must avoid situations that may lead to a conflict of interest and must report such situations to their managers.

 

4. IMPLEMENTATION AND MONITORING

Internal Audit: Regular internal audits are conducted to ensure the effectiveness of measures taken against bribery and corruption.

Training and Awareness: Employees receive regular training on anti-bribery and anti-corruption measures, and awareness programs are carried out.

Whistleblowing Mechanism: Türkiye Hayat Emeklilik encourages employees and third parties to report any suspicious activities related to bribery or corruption. Whistleblowers can submit reports to [email protected], and all reports are handled with confidentiality.

Retaliation Prohibition: No retaliation will be taken against anyone who makes a good-faith report, and their rights will be protected.

  

5. SANCTIONS

Disciplinary actions will be taken against employees who violate this policy; business relationships with company partners and suppliers who act in violation of the policy will be terminated, and if necessary, relevant parties will be reported to legal authorities.

6. ENFORCEMENT

This policy enters into force upon the approval of Türkiye Hayat Emeklilik A.Ş. Board of Directors. When necessary, the policy may be amended by the decision of the Board of Directors.