Gift and Hospitality Policy

Gift: Items or services given in the course of business life, which are not contrary to customary practices, and are given to show courtesy or appreciation, without requiring any monetary compensation.

Conflict of Interest: A situation where an employee, either implicitly or explicitly, receives an economic benefit, gift, or special treatment from the company’s stakeholders (such as agents, business partners, suppliers, and clients) that could potentially influence the employee's performance, impartiality, and decision-making process, or result in the employee, their family, or close associates obtaining financial or non-financial personal gain.

Representation/Hospitality: Meetings, meals, events, travel, or social organizations organized by the company or third parties for social, cultural, or business purposes.

Employees must act in accordance with the Türkiye Hayat Emeklilik Anti-Bribery and Anti-Corruption Policy and adhere to ethical standards.

No gifts may be requested from customers, business partners, or suppliers.

Hospitality and gifts should not impair impartiality in commercial relationships.

Cash gifts, precious metals, foreign currency, stocks, and checks are unacceptable.

Promotional products such as calendars, agendas, and pens given for marketing and promotional purposes are acceptable.

Any subsequent accepted gifts must be reported to the Internal Control Directorate under the Türkiye Hayat Emeklilik Risk Management Policy by the relevant manager.

Gift or hospitality offers should not be perceived as providing special treatment to the company or its employees.

To maintain impartiality in business relationships, gift exchanges between managers and employees within the company should be kept to a minimum.

Meals and events that are widely accepted and reasonable in the business world are acceptable, provided these expenses align with the company's representation expense limits.

When attending an event as an invitee and representative of the company, the official company employee's travel and accommodation expenses will be covered under the following conditions: there must be an ongoing or potential business relationship with the other party; the event must not be a one-off or occur regularly; the event must not be excessive or disproportionate; it must not be held in inappropriate locations; the entertainment activity must not hinder fair and impartial decision-making or cause it to be perceived negatively by others. Under these criteria, the costs may be paid by third-party organizers, and all information and documentation related to hospitality activities (participant information, business relationship details, event specifics, expenses, etc.) must be recorded accurately and transparently in the company's books and records. Employees should submit the documents related to the activity to the relevant department for safekeeping.

The General Manager is authorized to determine the procedures and principles regarding the gifts and promotions that the company will offer to third parties, including who will receive them and how they will be provided.