UNGC

• ILTEKNO supports and respects internationally proclaimed human rights.

• ILTEKNO conducts its activities in line with human rights principles and does not tolerate any violations.

• ILTEKNO supports employees' freedom of association and collective bargaining.

• ILTEKNO accepts working conditions that comply with ethical principles.

• ILTEKNO supports working conditions in accordance with the ILO Conventions and expects the same level of commitment from all its stakeholders.

• ILTEKNO adopts the principle of equality in recruitment and placement processes.

• ILTEKNO supports precautionary approaches to environmental challenges.

• ILTEKNO supports initiatives and activities that enhance environmental responsibility.

• ILTEKNO supports the development and dissemination of environmentally friendly technologies.

• ILTEKNO stands firmly against all forms of corruption, including bribery and extortion.

 

Ethics

CODE OF ETHICS REGULATION

The Code of Ethics encompasses the Company's fundamental principles of conduct. All activities of the Company are carried out within the framework of the ethical principles determined and approved by the Board of Directors.

The Code of Ethics constitutes an indispensable set of rules established to enhance service quality, ensure the efficient use of resources, prevent unfair competition, and strengthen relationships with employees.

The Board of Directors, executives, and all employees are obliged to comply with the Code of Ethics while performing their duties. In addition to business procedures, standards, laws, and regulations, the Company has established ethical principles based on its corporate values, which are considered complementary to these regulations.

Managers and employees are expected to uphold these fundamental values in all their professional relationships and activities and to contribute to maintaining the highest level of reputation for the Company, its shareholders, and its employees.

 

1. ACTIVITIES

Activities are carried out in accordance with the applicable legal regulations of the countries in which the Company operates, the Articles of Association, internal regulations and policies, and national and international standards.

Off-the-record activities are strictly prohibited. Accuracy and consistency in business records are fundamental principles.

All employees are expected to cooperate fully and support audit activities conducted to monitor compliance with legal regulations and internal policies.

 

2. MANAGEMENT PRINCIPLES

Customer Orientation

Maintaining a customer-centric approach at all times and prioritizing customer satisfaction.

Integrity

Ensuring transparent, clear, and accurate communication within the Company and with our customers and business partners.

Individual Development

Supporting continuous personal and professional development by following technological innovations, investing in research and development, and providing training opportunities.

Social Responsibility

Delivering solutions through optimum designs and environmentally friendly technologies.

Teamwork

Promoting a collaborative working environment by embracing the positive energy generated through team spirit.

 

3. STAKEHOLDERS

In relationships with customers, suppliers, and all individuals and organizations with whom the Company conducts business, the principles of honesty, trust, consistency, professionalism, independence, long-term collaboration, and mutual respect are observed.

The Company aims to provide products and services of superior quality that fully meet customer needs and expectations.

Only services that can genuinely be delivered are offered, and every effort is made to fulfill commitments.

The Company refrains from practices that restrict fair competition, does not disparage competitors' products, and does not engage in misleading advertising. Under no circumstances are unlawful or unethical methods used to obtain competitive information.

Confidential and proprietary information belonging to the Company, personal information of employees, and customer information are protected. Information and documents provided by the Company or obtained through one's position, including trade secrets, undisclosed financial and other information, employee records (including salaries and benefits), and confidential information contained in agreements with third parties, are considered confidential and are protected accordingly.

"Company Information" includes, but is not limited to:

• All software developed or licensed by the Company or third parties on behalf of the Company.

• Marketing and sales plans, product development plans, competitive analyses, benchmarking results, business and financial plans or forecasts, non-public financial information, contracts, customer information maintained by or on behalf of the Company, and employee lists.

• Inventions, technologies, know-how, experimental studies, R&D activities, ongoing development projects, and all information, documents, and materials related to procurement, logistics, accounting, trade, and licensing.

• Information related to Company facilities and production processes.

• Information belonging to subsidiaries or affiliated companies in which the Company has a direct or indirect ownership interest.

• Intellectual, financial, commercial, technical, and other confidential information that the Company is obliged to protect under legal agreements with third parties.

The Company takes utmost care to protect the personal data of its employees and stakeholders. Personnel records, corporate email correspondence, and communications conducted through Company-provided computers, telephones, and other communication devices are recorded by the Information Technologies Department and are used only by authorized personnel when necessary and within the scope of legitimate purposes.

Any unauthorized disclosure or use of confidential Company information or documents for insider trading or personal gain is strictly prohibited.

Upon termination of employment, employees are responsible for safeguarding all confidential information, documents, and Company property in their possession and must take all necessary precautions to prevent their use against the Company's interests.

4. HUMAN RESOURCES POLICY

The Company does not discriminate based on race, ethnicity, nationality, religion, age, disability, marital status, or gender in its human resources practices. Equal opportunities are provided to individuals under equal conditions regardless of their union membership or political affiliations. Performance and productivity are the primary criteria for compensation and promotion decisions, and an open-door policy is maintained.

Individuals who possess the professional qualifications required to perform their assigned duties are selected for managerial positions.

The Company rejects all forms of discrimination, forced labor, and coercive working practices throughout recruitment and employment processes.

Employees are provided with a safe and healthy working environment as well as opportunities for career development.

The Company is committed to treating all employees equally, providing a safe and comfortable workplace, and continuously improving working conditions through ongoing research and development efforts.

Training programs aimed at improving both employees’ professional competencies and personal skills are conducted in accordance with the principle of equal opportunity.

Employees are expected to communicate and collaborate with one another based on mutual trust, respect, and courtesy. In the event of any physical, sexual, verbal, or other forms of abuse being reported or identified, the Ethics Representative shall initiate the relevant procedures.

Employees' right to belong to a trade union, as recognized under the European Convention on Human Rights, is respected.

Business processes are managed in accordance with the legal regulations applicable in the countries and regions in which the Company operates.

ILTEKNO respects the human rights of all its stakeholders, including its employees and individuals working throughout its supply chain. Its fundamental principles are based on conducting business in compliance with laws and ethical standards and supporting every individual's right to be free from slavery, forced labor, or any form of coercion in the workplace. Child labor is strictly prohibited.

 

5. CONFLICT OF INTEREST AND ANTI-CORRUPTION

No employee shall yield to pressures that may adversely affect the interests of the shareholders or accept any material benefit.

Employees shall act with the utmost diligence in managing expenses and demonstrate a strong awareness of cost efficiency and savings.

Employees shall perform their duties impartially and in the best interests of the Company without allowing personal, familial, or external interests to influence their decisions.

Employees must avoid situations that may give rise to conflicts of interest and immediately inform their managers should such situations arise.

Employees must refrain from obtaining unfair profits or personal gains by abusing their position or authority for the benefit of themselves or third parties.

Employees who have first-degree family members in decision-making positions within companies operating in the same sector or who have ownership interests in other companies are required to disclose such circumstances to the Ethics Committee.

 

6. SOCIAL RESPONSIBILITY, ENVIRONMENT, OCCUPATIONAL HEALTH AND SAFETY

The Company acts responsibly regarding environmental protection, preservation of natural life, consumer rights, and public health, and complies with all applicable regulations.

Employees are expected to use energy and natural resources efficiently and responsibly.

Solutions aimed at preventing pollution at its source are developed and implemented whenever possible.

The Company complies with all applicable national and international environmental legislation and regulations.

All employees, customers, and subcontractors are encouraged to contribute to raising environmental awareness.

From the design stage through production and use, materials and technologies that minimize adverse environmental impacts are selected and implemented.

Projects are developed to fulfill the Company's social responsibilities, and collaborations are established with organizations working toward these objectives.

Occupational Health and Safety is ensured through the active participation and visible leadership of all ILTEKNO employees.

In line with the principle that "There is always a safer way to do every job," the Company supports continuous improvement initiatives in occupational health and safety and conducts regular inspections and activities to prevent all workplace accidents.

Projects that contribute to economic and social development are actively supported.

7. RESPONSIBILITIES

ALL EMPLOYEES

All employees shall perform their duties in an equitable, transparent, accountable, and responsible manner.

Relationships among employees shall be based on mutual respect, trust, and cooperation.

Company resources and facilities may not be used to support political activities. Political activities may not be conducted within the Company, donations may not be made to political parties, and political campaigns may not be supported.

Political, social, and religious views shall not become subjects of discussion within the workplace.

Employees may not engage in secondary employment or provide services to another company during working hours without the approval of the Board of Directors and the Ethics Committee. However, employees are encouraged to fulfill their social responsibilities. For this purpose, and subject to the approval of the Board of Directors, employees may serve in public service associations, foundations, professional organizations, or educational institutions.

All employees are responsible for protecting and enhancing the Company's reputable image. Accordingly, employees are expected to ensure that their personal conduct complies with applicable laws and generally accepted moral principles.

Employees may not use confidential or non-public Company information for their own benefit or for the benefit of others.

Employees may neither accept nor offer gifts with a value exceeding EUR 100 that may put the Company or its brand in a difficult position. Promotional gifts approved by the Management (e.g., agendas, pens, calendars, etc.) are acceptable.

Consumable gifts such as food and beverages shall be shared within the relevant department. In cases where gifts of material value are received, appropriate action shall be taken upon consultation with the Board of Directors.

The Company strictly prohibits bribery, corruption, abuse of office, and all other unethical or unlawful conduct, while supporting national and international efforts aimed at combating such misconduct.

Employees may not obtain direct or indirect benefits from Company-related business activities or accept any benefits, assistance, or loans from individuals or organizations with whom the Company maintains business relationships.

Email is an important internal and external communication tool. Email records are strictly confidential unless disclosure is required by law. Employees are solely responsible for any unlawful content, attachments, or messages included in their emails.

Employees shall comply with the Company's information technology policies. The use of unlicensed software and inappropriate websites for non-business-related internet activities is prohibited. Employees are expected to adhere to all connection and cybersecurity requirements.

Employees are responsible for protecting Company assets (including cash, computers, mobile phones, company vehicles, and fixed assets) and ensuring that they are used efficiently and economically. Company assets may only be used for business purposes.

Tampering with official documents prepared while performing Company duties is strictly prohibited.

Employees who lose their employment due to unlawful or disgraceful criminal conduct may not be employed in another position within the Company or any affiliated group companies.

No employee may use alcohol or narcotic substances in a manner that adversely affects job performance.

Following the termination of their employment contract, employees may not enter into any business relationship with the Company for a period of two years without the approval of the Board of Directors.

All newly hired employees shall be informed of these ethical rules. Employees who witness conduct that falls outside the scope of the Code of Ethics must report it to their manager and/or the Ethics Representative. A copy of these rules shall be provided to all employees, who are required to sign an undertaking acknowledging that these ethical rules constitute an integral part of their employment agreement.

 

RESPONSIBILITIES OF MANAGERS

In addition to the responsibilities defined in their job descriptions, managers at ILTEKNO shall assume the following responsibilities:

• Establishing and maintaining a working environment and corporate culture that support the implementation of the Code of Ethics within their teams and developing business processes accordingly.

• Setting an example in the implementation of ethical principles, guiding, training, and supporting their teams, and referring relevant matters to the Ethics Committee when necessary.

 

RESPONSIBILITIES OF THE HUMAN RESOURCES AND BUSINESS SUPPORT DEPARTMENT

• Informing all employees about the ILTEKNO Code of Ethics Regulation and providing periodic training programs to ensure its implementation and adoption.

• Ensuring that newly hired employees are informed about the ILTEKNO Code of Ethics Regulation and that all employees formally acknowledge and approve it.

 

RESPONSIBILITIES OF THE BOARD OF DIRECTORS

The Board of Directors is responsible for ensuring the effective implementation and support of the rules established under the ILTEKNO Code of Ethics Regulation.

All policies covered by the ILTEKNO Code of Ethics shall be reviewed, updated, and documented by the Human Resources and Business Support Department based on the opinions of the Board of Directors. Current revisions shall be published to all relevant parties upon the approval of the Board.

The Board of Directors shall ensure the confidentiality of all reports submitted under the ILTEKNO Code of Ethics Regulation.

The Board shall ensure the job security of employees who submit reports or notifications.

The Board shall ensure that all reports are investigated promptly, fairly, impartially, and diligently, and that appropriate actions are taken in cases of violations.

 

8. VIOLATIONS OF THE ILTEKNO CODE OF ETHICS REGULATION

In cases where employees act in violation of the ILTEKNO Code of Ethics Regulation, disciplinary proceedings may be initiated, which may result in the termination of employment.

Investigation procedures shall also be initiated against individuals who knowingly fail to report violations to the appropriate authorities, prevent the initiation of relevant processes, or approve and manage non-compliance with the Code of Ethics.

 

NON-RETALIATION POLICY

Employees who are subjected to retaliation as a result of making reports or notifications must immediately report such incidents.

Retaliation constitutes a violation of the ILTEKNO Code of Ethics Regulation and shall be treated accordingly.

 

ETHICS REPRESENTATIVE

The Ethics Representative is responsible for investigating all reports concerning violations of the ILTEKNO Code of Ethics Regulation and reports directly to the Chairman of the Board of Directors. The Ethics Representative is appointed by the Chairman of the Board.

The Ethics Representative is obliged to maintain the confidentiality of all reports and the identities of reporting employees.

Investigations shall be conducted confidentially.

Appropriate measures shall be taken to protect the rights of employees who are subject to investigation in the event that a report is ultimately determined to be unfounded.

The Ethics Representative is authorized to request information, documents, and evidence related to investigations and to analyze such materials within the scope of the investigation.

All processes, information, and documentation related to investigations shall be properly recorded.

Reports shall be evaluated promptly upon receipt. Where necessary, investigations shall be initiated without delay and concluded as quickly as possible.

Recommendations made by the Ethics Representative for preventive and corrective actions shall be implemented promptly.

All relevant parties and authorized individuals shall be informed of the outcome of investigations.

The Ethics Representative shall perform their duties independently and impartially and shall not be subject to hierarchical influence or pressure within the organization.

Where expert opinions are required, the Ethics Representative may consult subject matter experts, provided that confidentiality is maintained and appropriate safeguards are implemented.

 

REPORTING VIOLATIONS OF THE ILTEKNO CODE OF ETHICS REGULATION

For all questions and reports concerning the ILTEKNO Code of Ethics Regulation, the Ethics Representative may be contacted via the following email address:

Email: ethics@iltekno.com

 

ENTRY INTO FORCE

This Regulation shall enter into force upon being signed and approved by the members of the Board of Directors.