Business Ethics Codes and Application Principles

1.General Provisions

1.1. Purpose

The purpose of this booklet is to place ethics culture, to determine codes of conduct that the employees within ARENOL need to comply while performing their tasks and to help them to act in accordance with these principles.

1.2. Scope

“Business Ethics Code” covers all managers and employees including Members of Board of the company and subsidiaries and all of these persons will be referred to as “employees” below.

2.Our Basic Business Ethics Values and Principles

2.1. Integrity and Reliability 

Honesty and reliability are our primary value in all our business processes and relations. Our employees act in accordance with laws of Republic of Turkey, international legal rules and moral values while they reach company objectives.

2.2. Confidentiality 

As ARENOL employees, we care confidentiality and protection of private information of our customers, colleagues and other persons and organizations that we work together with. We protect confidential information of company activities, use these information only in accordance with ARENOL purposes and share with authorized persons. We do not transfer works such as confidential information, documents, regulations and projects of company, use for our interests against ARENOL while leaving the company.

2.3. Justice and Equality 

We treat fairly to our shareholders and each other, we prevent discrimination. As ARENOL employees, we do not take any notice of differences such as race, nationality, language, religion, gender and social status between customers, subcontractors and suppliers, and avoid from prejudiced attitudes.

2.4. Productivity 

We utilize from existing sources to reach company objectives and work as result-oriented. We use time properly to be more efficient and productive while doing a job, dedicate ourselves to our jobs, complete that job as possibly as the best and most successfully and seek the ways to do the job better. We measure our performance fairly and attentively, set realistic and reachable goals and evaluate our performance in accordance with these goals.

2.5. Open Door Policy 

We resolve many issues before they become problems in ARENOL. “Open Door” policy encourages employees to explain their ideas and opinions, to mention their worries and complaints and to ask questions under the condition of remaining in legal and ethical limitations. All managers support this policy by “keeping their door open” for their subordinates and other personnel who want to reach them.

3.Business Ethics Codes

3.1 Conflict of Interest

We observe and prevent the situations where interest of ARENOL and persons and organizations related to ARENOL may conflict. It is among the most important responsibilities of all employees not to use company resources, name, identity and power for personal benefit, and to avoid situations that will adversely affect the name and image of the organization.

3.1.1. Engaging in Activities That Might Create Conflict of Interest

Employees cannot enter into business relations with their family members of third-degree relatives (uncle, aunt or niece and nephew). In case the specified persons’ companies or companies where they work have business partnership with ARENOL, ARENOL employees do not take part in any decision process related to these companies. In this case, the subject must be notified to relevant department manager and Local Ethics Consultant in advance. It is subjected to information and approval of Members of Board except for exceptional circumstances.

It is against the Business Ethics Codes that employees are in the position of manager or supervisor with people with whom they have a close relationship with kinship or a similar bond. The managers who have authority to recruitment and decision making cannot hire their spouses and close relatives (to third-degree relatives). In this case, the matter must be notified to department manager. It is subjected to information and approval of Members of Board except for exceptional circumstances.

3.1.2. Working Outside The Organization

It is essential for employees in ARENOL not to work directly or indirectly in jobs to be considered as “tradesman” or “craftsman” and not to work for other persons and/or organizations in and out of working hours for a fee or similar interests. In case where ARENOL employees are members of board or auditor in companies other than ARENOL, this subject must be notified to Board in advance. Employees cannot take charge in rival or other companies who have business relationship with ARENOL without approval of Board.

3.1.3. Misconduct 

Employees cannot use their authorities for the benefit or themselves or their relatives cannot damage ARENOL by exceeding their authorities. Employees cannot directly or indirectly generate personal income through third persons from all works and contracts to which ARENOL is a party, such as activities, purchases and sales. They cannot use the opportunities (credit card, vehicle, driver etc.) given to them due to their duties for their special objectives, cannot act and behave against moral, law and company disciplinary.

3.1.4. Resource Utilization 

In resource utilization to be made on behalf of the company, company assets, facilities and personnel without company interest regardless of the name. “Savings in every respect” principal is applied by all personnel. ARENOL employees use the time well during business hours, do not spare time for personal affairs. Managers do not appoint employees for their personal affairs. It is essential not to accept personal visitors during business hours. Employees completes their meetings for mandatory visitors related to subject of visit and in a reasonable time without effecting the work flow.

3.1.5. Relations with Other Persons and Organizations That the Company Has a Commercial Relationship 

A special relationship cannot be entered with ARENOL customers, suppliers, contractors and other persons and companies that the ARENOL has a commercial relationship, a loan of money, special discounts, goods or services for personal purpose cannot be taken and given.

ARENOL bases its commercial relations on professionalism, honesty, seriousness, politeness and reliability. Insulting, discriminating and offensive attitudes must be avoided in all kinds of written or verbal interaction.