Procedure Preventing Bribery and Corruption

Procedure Preventing Bribery and Corruption

Purpose

The purpose of the Anti-Bribery and Anti-Corruption Policy is to set forth anti-bribery and anti-corruption policies to prevent bribery and corruption.

Scope

The anti-bribery and anti-corruption policy covers:

  • All Adoksan Tekstil employees, including the Board of Directors of Adoksan Tekstil,
  • Companies from whom we purchase goods and services and their employees, and the persons and organizations working on behalf of Adoksan Tekstil, including suppliers, consultants, lawyers, and external auditors.
Definitions

Corruption is the abuse of power, directly or indirectly, for gaining any kind of personal gain. Bribery, on the other hand, is when a person gains an advantage for himself or for the party requesting it, or for another person due to this relationship, within the framework of an agreement with another person in order to act contrary to the requirements of his/her duty in ways such as providing, offering or promising, requesting or accepting benefits directly or through intermediaries, or intermediating them in order to perform, have them performed, not to perform, speed up or slow down a job related to the performance of their duty.

Bribery and corruption can take place in many different ways, including:

  • Cash payments,
  • Political or other donations,
  • Commission,
  • Social rights,
  • Gift, entertainment,
  • Other benefits.
Duties and Responsibilities

Implementation and updating of the Anti-Bribery and Anti-Corruption Policy is under the authority, duty and responsibility of the Board of Directors. Within this framework;

  • The personnel manager is required to provide advice to the Board of Directors to establish an ethical, reliable, legal and controlled work environment,
  • The senior management should evaluate their risks in accordance with the principles to be determined by the Board of Directors and establish the necessary control mechanisms,
  • In case of non-compliance with policies, rules and regulations, notification, review and sanction mechanisms should be determined and operated.
In addition, all Adoksan Tekstil employees are obligated to
  • Comply with the policies determined by the Board of Directors,
  • Effectively manage the risks related to their field of activity,
  • Work in compliance with relevant regulations and Adoksan Tekstil practices.
Companies from Which Goods and Services are purchased and sold

Companies that buy and sell goods and services are obligated to comply with the principles of procedure and other relevant legal regulations, and works conducted with persons and organizations that do not comply with these shall terminated.

Policy and Procedures
6.1 Bribery and Corruption

Adoksan Tekstil is against all forms of bribery and corruption. It is absolutely unacceptable to take or give bribes, regardless of their purpose. The business relationship with third parties who wish to do business with Adoksan Tekstil through bribery or corruption should discontinued.

6.2 Gifts

A gift is a product that does not necessarily have to be a monetary payment, and is generally given as a way of thanking or as a commercial courtesy by people or customers with whom business relations are made. All kinds of gifts offered or given by Adoksan Tekstil to third parties must be offered publicly, in good faith and unconditionally. The same principles apply to accepting gifts, and gifts should not be accepted, except for symbolic gifts of low monetary value, which are stated in these principles. In addition, even within this scope, the acceptance of gifts should not be frequent, and the HR and senior management of the company should be notified by the acceptor about the accepted gifts through his/her first supervisor.

6.3 Facilitation Payments

Persons and organizations covered by this Policy shall not offer facilitation payments to secure or speed up a routine transaction or process (obtaining permits and licenses, obtaining documents, etc.) in government agencies.

Accurate Record Keeping

The matters that Adoksan Tekstil has to comply with regarding the accounting and recording system are regulated by legal regulations. Accordingly:

  • It is required to record and keep all kinds of accounts, invoices and documents regarding relations with third parties (customers, suppliers, etc.) in a complete, precise and accurate manner,
  • Accounting or similar commercial records of any transaction should not be tampered with and the facts should not be distorted.
Notification of Policy Violations

If there is an opinion or suspicion that an employee or a person acting on behalf of Adoksan Tekstil is acting against this policy, the person in question should be notified the Human Resources and Worker representative.

Adoksan Tekstil encourages an honest and transparent approach, supports any employee or person acting on behalf of Adoksan Tekstil who expresses their sincere concerns in good faith, and keeps the notifications confidential. Information about the employee who made the notification is not included in the documents or processes in any way. No employee may be subjected to pressure or punishment for reporting. The notifying person is required to communicate this if he or she has been subjected to such treatment.

The companies or business partners from which goods and services are purchased must also remind their employees regularly and encourage them to make notifications if they encounter such situations. This issue shall also guaranteed by the contracts made.

Policy Violations

In cases that are or may be against the policy, the issue shall be examined and necessary sanctions shall be applied in case of inappropriate behaviour. In case it is determined that there is a behaviour, attitude or activity contrary to the Procedure in the contracts made with the companies from which goods and services are purchased and sold to, or with persons and organizations working on behalf of Adoksan Tekstil, provisions stating that the works / contracts in force will be terminated unilaterally by Adoksan Tekstil with valid ground shall be included and these provisions shall be applied without exception in case of violation of the Procedure.