1. PURPOSE AND SCOPE OF APPLICATION
1.1 PURPOSE
The purpose of this policy is to outline the principles and practices of OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ in combating bribery and corruption and to ensure that these practices are communicated clearly and transparently. This policy aims to identify, reduce, and manage bribery and corruption risks in compliance with legal regulations, ethical and professional principles, and universal rules.
1.2 SCOPE
The anti-bribery and corruption policy applies not only to company employees but also to all business partners acting on behalf of the company or providing services to the company. In this regard, this policy covers OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ, its Board of Directors, shareholders, subsidiaries and affiliates, agents, representatives, customers, dealers, suppliers, contractors, and all other parties with whom it does business.
The OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ Code of Ethical Conduct and Application Principles are an integral part of this policy. This policy commits to adhering to the principles we have pledged to follow in line with the United Nations Global Compact, as well as compliance with the Company’s other internal regulations and legal regulations.
1.3 DEFINITIONS
Acts of corruption include “giving, offering, promising, receiving, accepting, requesting, or soliciting money, gifts, or any other benefit, whether monetary or non-monetary, for the purpose of obtaining or maintaining an advantage in the course of business activities.”
A corruption offense may result not only in penalties for those who commit the offense but also in legal or criminal penalties for their managers and the companies they represent if they have violated their supervisory duties at the time the offense was committed.
It should be noted that corruption acts include bribery.
Bribery refers to the provision of material or moral benefits to oneself or another person, either directly or indirectly, within the framework of a verbal or written agreement, with the aim of causing a person to perform an action that is contrary to the requirements of their duties or outside the normal course of business, such as performing, not performing, accelerating, or slowing down a task. Benefits that may be considered bribery can take many different forms, such as cash, gifts, event invitations or tickets, debt forgiveness, or donations for charitable purposes.
2. VIOLATION OF ANTI-BRIBERY AND ANTI-CORRUPTION RULES AND CONSEQUENCES
All our employees and all business partners defined within the scope above are required to be aware of the rules set forth in this policy and to act in accordance with these rules and the applicable laws and regulations on combating bribery and corruption while conducting their business. In the event of a violation of this policy, criminal penalties will be imposed depending on the nature of the incident.
Employees or business partners who refuse to participate in a bribery or corruption incident or who report a bribery or corruption incident will not be subjected to any negative consequences. In such a case, the reporting channels specified in this policy must be used.
3. DUTIES AND RESPONSIBILITIES
3.1 Employees and Business Partners
All employees and business partners must act in accordance with the principles set forth in this policy document. Managers must ensure that the principles set forth in this policy document are understood, implemented, and upheld by the business partners and employees under their supervision. Employees and business partners may not be compelled under any circumstances or by anyone to act in violation of this policy.
All employees and business partners must be vigilant regarding any signs of bribery and corruption.
3.2 OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ Ethics Committee
Within the scope of the Anti-Bribery and Anti-Corruption Policy, the OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ Ethics Committee is responsible for the following matters:
Developing, defining, publishing, and monitoring an effective anti-bribery and anti-corruption program,
Providing opinions on anti-bribery and anti-corruption issues,
Adopting policy rules, making necessary additions in accordance with all relevant legal and regulatory requirements, and coordinating activities to ensure the proper implementation of policy rules,
Ensuring that the necessary communication channels are established for reporting conduct that violates the policy text, and taking measures to ensure the confidentiality and security of the persons making the reports,
Ensuring that the necessary investigations and inquiries are conducted regarding complaints, reports, and allegations received on the subject.
3.3 Reporting and Information Sharing
Issues covered by the anti-bribery and corruption program specified in this policy, as well as reports and investigation results related to acts of bribery and corruption, are stored in a central database and reported periodically.
4. ANTI-BRIBERY AND CORRUPTION PROGRAM
OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ is committed to complying with laws and regulations, universal legal rules, and ethical and professional principles regarding bribery and corruption. Within the scope of this principle, OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ operates with a “zero tolerance” approach to bribery and corruption and is committed to conducting its activities fairly, honestly, and in compliance with legal and ethical principles. This Anti-Bribery and Corruption Policy has been implemented as a result of the importance placed on this issue.
Within the scope of the anti-bribery and corruption policy, activities are carried out and necessary measures are taken to fulfill the following:
Training and awareness programs are conducted for employees and business partners regarding the legal requirements related to the anti-bribery and corruption program. Secure and accessible communication channels are provided for employees to report suspicious situations.
OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ prohibits any payment made to facilitate or expedite any transaction. OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ employees do not tolerate the offer, promise, request, demand, giving, or acceptance of such offers by third parties.
Without the necessary approvals (specific or general for a particular level of gift/entertainment), offering, promising, or giving gifts, entertainment, hospitality, or any other benefit, whether direct or indirect, to government or public officials, whether foreign or domestic, is not permitted.
Business partnerships are developed with parties that are deemed to protect OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ’s reputation and comply with OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ’s anti-bribery and anti-corruption policy. In this context, before establishing any business partnership, including mergers and acquisitions, or appointing a representative, the counterparty in question is assessed for bribery and corruption risks and business ethics.
Individuals, suppliers, dealers, contractors, etc., who establish relationships with OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ and act on its behalf, must agree to comply with all applicable legal regulations and our anti-bribery and anti-corruption policy. To ensure this, relevant provisions are included in the contracts.
OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ monitors individuals and companies on blacklists created based on information received from public authorities, international data providers, and social media sources to ensure compliance with applicable regulations and the company’s own rules. Contacts should not be established with individuals or organizations suspected or suspected of bribing third parties. If such a relationship already exists, it should be terminated immediately as of the date the information is received.
In conducting business with private or public individuals and organizations seeking to establish or maintain a business relationship with OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ, no gifts or entertainment should be accepted or offered, other than generally accepted promotional materials, that could create the impression of impropriety, create a relationship of dependency, or be perceived as such. Similarly, no discounts or benefits of any kind that could be perceived as inappropriate should be requested or offered from suppliers, dealers, authorized service providers, customers, or any third party, and should not be accepted when offered.
However, if it is determined that rejecting the aforementioned gift or entertainment is impractical or would have an undesirable outcome for the business relationship, acceptance and use of such a gift may only be approved with the written approval of the relevant manager. If the gift is accepted, if it is of significant value, consideration should be given to donating it to a charitable organization.
To avoid the appearance of bribery or corruption, any job offer made by OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ must be conducted within the competitive recruitment processes established by company procedures. Job offers should not be made to customers, business partners (or third parties closely associated with them), or government officials or public officials.
Donations for political purposes may not be made on behalf of OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ. Charitable contributions and sponsorships made by OKYANUS ÇORAP SANAYİ VE TİCARET ANONİM ŞİRKETİ must be legal, comply with company regulations, policies, directives, and regulations, and comply with applicable local laws.
The effectiveness of the anti-bribery and corruption program is regularly reported.