Our Code Of Business

OUR CODE OF BUSINESS

A. HONESTY

Accuracy and honesty are our priority values ​​in all our business processes and relationships. We act with integrity and honesty in our relationships with employees and all our stakeholders.

B. SECRECY

Confidential and private information; It includes information about Yücel Culture Foundation which may cause disadvantage in terms of competition, trade secrets, financial and other information not yet disclosed to the public, personnel personal rights information and information under the "confidentiality agreements" concluded with third parties.

As Yücel Cultural Foundation employees; we take care to protect the privacy and confidentiality of our customers, employees and other related persons and organizations. It is absolutely unacceptable for us to obtain any commercial interest through the leakage of any confidential information belonging to the Yücel Cultural Foundation. When leaving our company, we have confidential information and documents that we have due to our duties, as well as projects, regulations, etc. we do not take the work out.

C. CONFLICT OF INTEREST

As Yücel Culture Foundation employees, we aim to avoid conflict of interest. Taking advantage of our current task; personally, we do not gain personal benefit from the persons and organizations with whom we have business relations through our family or relatives. We do not engage in any business activity based on an additional financial interest other than the Yücel Culture Foundation. We refrain from using the name and power of the Foundation, our Foundation identity for personal benefit.

We apply these methods when we believe that in the event of a potential conflict of interest, the interests of the parties concerned can be safeguarded through legal and ethical methods. In case of doubt, we consult our manager, the Board of Directors or the Ethics Committee.

D. OUR RESPONSIBILITIES

In addition to our legal responsibilities; we take care to fulfill the responsibilities listed below on behalf of the foundation to the persons we have relations with, employees, donors, suppliers and business partners, solution partners, society, humanity and other non-governmental organizations.

1. Legal Responsibilities

All of our domestic and international activities and operations are carried out by Turkish Republic laws and international law, we provide timely, accurate and complete information to legal regulatory agencies and organizations.

In carrying out all of our activities and transactions, we are located at equal distance to all public institutions and organizations, administrative formation, non-governmental organizations and political parties without any expectation of interest and we fulfill our obligations with this responsibility awareness.

2. Responsibilities Against Our Members

We work with a proactive understanding that responds to the satisfaction of our members, our members and requests in the shortest time and in the most accurate way. We offer our services on time and on our promise; We treat our members with respect, honor, justice, equality and courtesy.

3. Responsibilities Against Our Workers

We ensure that employees' personal rights are fully and correctly exercised. We treat employees honestly and fairly, and commit ourselves to a non-discriminatory, safe and healthy working environment. We make the necessary efforts for the personal development of our employees, support them to volunteer for appropriate social and social activities with the awareness of social responsibility, and observe the balance between business and private life.

4. Responsibilities Against Our Trustees

By giving priority to the continuity of the Foundation and in line with its goal of creating value for the Foundation; we avoid taking unnecessary or unmanageable risks and aim for sustainable benefit. We act within the framework of financial discipline and accountability, and manage our working resources, assets and working time with the awareness of efficiency and savings. We strive to increase our competitiveness and invest in areas that have the potential to grow and provide the highest yield to the connected resource. In our public statements and to our Trustees; We provide timely, accurate, complete and understandable information about our financial statements, strategies and investments.

5. Responsibilities Against Suppliers, Service Providers and Business Partners

We behave in a fair and respectful manner as expected from a good customer and take due care to fulfill our obligations in a timely manner. We carefully protect the confidential information of our business partners and business partners.

6. Responsibilities Against Society and Humanity

Protection of democracy, human rights and the environment; education and charity, the elimination of crime and corruption is very important to us. Acting sensitively as a pioneer in social issues with the awareness of being a good citizen; non-governmental organizations, services for the benefit of the public, we try to take part in appropriate activities on these issues. We will be sensitive to culture and traditions of the countries in which we conduct international projects and Turkey. We do not provide and accept products and services, bribes or gifts, etc.

II. POLICIES SUPPORTING CODE OF BUSINESS

A. Conflict of Interest Policy

It is essential that the employees of the Yücel Culture Foundation stay away from situations that may create a conflict of interest. One of the most important responsibilities of all employees is to avoid the use of personal resources of the sources, name, identity and power of the foundation, and to avoid situations that may adversely affect the name and image of the organization. The following principles of practice determine the situations of conflict of interest that Yücel Culture Foundation employees may encounter in their private lives when performing their duties or due to their business relationships and the principles to be applied in these situations.

Code of Practice

1.  Activities That Might Cause Interest of Conflict

All Yücel Culture Foundation employees are required to fully comply with the conditions and principles set out below as activities that may create a conflict of interest. The Foundation carries out the necessary activities to encourage its employees to comply with these principles.

I. Being Involved In An Activity That Might Cause Interest of Conflict

Employees do not engage in any business relationship with family members, friends or other third parties with whom they have a mutual or unrequited interest. For example, an employee with a purchasing authority should refrain from doing business with a supplier with one of the family members. Exceptional cases are subject to the knowledge and approval of the Chairman of the Board of Directors of the Foundation. Employees shall not obtain any commercial interest by leaking any information belonging to the Yücel Culture Foundation from inside, nor be instrumental in obtaining the benefit of others.

It is essential that the employees of the Yücel Culture Foundation do not engage in activities that require direct and indirect means to be considered as "tradesman" or "craftsman", and that they do not work for any other person and / or institution within or outside working hours under any name for a fee or similar benefit. However, employees may work outside the working hours for another person (family member, friend, other third parties) and / or the organization for remuneration or similar benefits under these circumstances;

• If it does not create a conflict of interest with the duties they carry out in the Foundation and other Yücel Culture Foundation practices,
• If it is in compliance with other business ethics rules and policies supporting these rules,
• If it does not adversely affect the continuation of their duties at the Foundation,
• If  there is a written approval of the board of directors.

It is possible for employees to work in any political party with the following conditions and written approval of management;

• Employees may not engage in any political activity during the working hours and may not take the time of their colleagues.
• Employees may not use the name of the Foundation, position, title and resources of the Yücel Cultural Foundation during their political activities.

II. Malpractice

It is unacceptable for the employees to use the powers of their own and / or their relatives to the benefit of their interests and harm to the Foundation, other than as expected.

Employees may not directly or indirectly gain personal gain from the Foundation's purchases and activities and all transactions and contracts to which it is a party.

Employees shall not engage in acts or conduct contrary to morality, law or the discipline of the Foundation.

III. Usage of Sources

In the use of resources on behalf of the Foundation, the interests of the Foundation are taken into consideration. The assets, facilities and personnel of the Foundation cannot be used outside the Foundation, regardless of the name and benefit of the Foundation. The principle of "saving on everything" applies by all staff.

Correct use of resources for the benefit of the Foundation also requires the correct use of time. During the working hours, the employees of the Foundation make good use of the time and do not allocate time for their private works during the working hours. Managers cannot assign employees for their personal business.

It is essential that no special visitors are accepted during working hours. Employees are required to complete the interviews for mandatory visitors in a reasonable time in connection with the subject of the visit and without hindering the workflow.

IV. Relations With Other Persons And / Or Organizations With Which The Foundation Has Commercial Relations

Personal money and / or goods / services may not be taken and personal loans and / or institutions may not be borrowed, goods / services cannot be provided from private business relations with the Foundation, its subcontractors or suppliers and other persons and / or organizations with which the Foundation has commercial relations.

The staff of the Foundation may not request or imply gifts from other persons and / or organizations with whom the Foundation has commercial relations; Any gifts, money, checks, property, free holidays, special discounts, etc. that will put the Foundation under obligation cannot be accepted. Personal assistance and donations from any person or organization that has a business relationship with the Foundation cannot be accepted. In the cases such gifts are accepted, Gift Acceptance and Giving Gift Policy applies.

V. Media And Relationships

Relations with the media are based on the Foundation Communication Strategy.

To give an interview, interview, seminar-conference etc. to participate as a speaker depends on the approval of the Board of Directors of the Foundation. No personal gain can be obtained from these activities.

B. Gift Acceptance and Giving Gift Policy

It is essential that the Yücel Culture Foundation and its employees do not accept gifts or benefits that may affect their impartiality, decisions and behavior, and that they do not attempt to provide gifts and benefits to third parties and organizations that may create such effects. The principles of implementation described below regulate the gift exchanges of the employees of the Foundation with the third persons and organizations with which they have business relations and determine the principles to be applied in this regard.

Code of Practice

1. It is forbidden for the employees of the Foundation to receive all kinds of benefits and gifts that affect or have a negative impact on their impartiality, performance, decision-making, or have economic value in the course of their duties.

2. Under the following circumstances;

• Compatible with corporate business objectives
• In accordance with current legislation
• If the public will learn that the gift, it will not leave the Foundation in a difficult position.

Foundation employees may receive and / or give gifts outlined in Article 3, or they may agree to be subject to special practice.

3. Provided that it complies with the conditions specified in Article 2;

• The employees of the Foundation can provide and receive entertainment, catering and food at acceptable standards in the business world.
• In the seminars and similar organizations that are represented on behalf of the Foundation, in addition to money, the symbolic value of the award, the shield, etc. gifts can be received.

4. In the above-mentioned circumstances and other gifts, interests, holidays, discounts, etc., other than money, etc. approval is not required if the total value of the gifts received is less than 250 TL for each calendar year and the person / institution giving the gift separately, provided that it complies with the conditions listed in Article 2.

5. It is forbidden to receive gifts or benefits implicitly or explicitly linked to a provision.

6. Under no circumstances can it be accepted to receive, give or offer bribes and / or commissions.

7. It is forbidden for foundation employees to accept unpaid or borrowed money from subcontractors, suppliers, consultants, competitors or customers, and to cover travel expenses, activity expenses and similar payments.

8. The Board of Directors of the Foundation approves the gifts and promotional materials to be given to the members, donors and other third parties with whom the business relationship exists. There is no need for permission to distribute approved gifts and promotional materials.

9. The Foundation may accept the appropriate products and services as gifts, provided that it complies with the conditions set out in Article 2, and products or services that comply with the culture and ethical values ​​of the buyer may be given as gifts, within the knowledge and approval of the Foundation's Board of Directors.

10. In exceptional cases where local cultural values ​​require mutual gifts above the values ​​specified in the Foundation's policy, such gifts may only be accepted on behalf of the Foundation and with the approval of the Foundation's Board of Directors. In any case, the exchange of gifts must be made in accordance with the local culture.

C. Confidential Information Protection Policy

Knowledge is one of the most important assets of Yücel Culture Foundation to use in order to realize its vision. Accordingly, it is the collective responsibility of all our stakeholders and employees to ensure the effective use, correct sharing of information and ensuring the confidentiality, integrity and accessibility of information in this process. The management systems established for the management and confidentiality of information in our Foundation and the harmonization of the processes applied with each other are important for the highest benefit of the Foundation. Through details of the applications related to the subject below; It defines confidential information for the Foundation and sets out the principles that employees must comply with regarding confidential information.

Code of Practice

Confidential Information includes, but is not limited to, Trademark and so on, intellectual property, database, printed communication materials, processes, advertisements and labels and plans (marketing, product, technical), business strategies, strategic partnerships and financial information, written, developed, made or implemented by the personnel including all kinds of innovations. personnel information, member and donor lists, product designs, know-how, specifications, supplier information, etc. any written, graphic or machine readable information.

The principles to be followed regarding confidential information are;

1. This information may not be disclosed to third parties unless required to be disclosed in accordance with the Official Authorities and Legislation.
2. This information cannot be changed, copied or destroyed. Necessary precautions are taken to keep the information carefully, to keep it and not to reveal it. Changes to the information are recorded together with their history.
3. The confidential files cannot be taken out of the institution. For the confidential information that needs to be taken out of the institution, the person responsible for the information or the approval of the Board of Directors should be obtained.
4. Passwords, user codes and similar identifying information used to access foundation information are kept confidential and not disclosed to anyone except authorized users.
5.  The confidential information of the foundation is not discussed in dining halls, cafeterias, elevators, service carts and similar public places.
6. Confidential information is classified according to the degree of confidentiality and is clearly stated in the content of this information. The staff of the foundation knows the degree of confidentiality of the information obtained in accordance with their duties and acts in accordance with this confidentiality. If there is any doubt about the degree of confidentiality, it is treated according to the upper class of privacy and the opinion of the relevant manager is obtained when necessary.
7. In the event that information is shared with third parties and / or organizations for the benefit of the Foundation, a confidentiality agreement is signed or a written confidentiality agreement is obtained from the other party in order to ensure the understanding of their responsibilities regarding the security and protection of shared information.
8. No false statements and / or gossip about individuals or institutions is allowed.
9. Wages, benefits and similar personal information of the personnel reflecting the foundation policy are confidential and cannot be disclosed to anyone except the authorities. Personnel information is sent to the person privately. It is strictly prohibited for staff to disclose this information to others or to pressure other employees to disclose the information.

D. Creating and Maintaining a Fair Working Environment Policy

Yücel Cultural Foundation considers creating and maintaining a fair working environment as one of its most important priorities. It is aimed to increase the success, development and loyalty of the employees by creating a fair, respectful, healthy and safe working environment in compliance with all relevant laws and regulations. The following guidelines set out the basic principles for the establishment and maintenance of a fair working environment in the Foundation.

Code Of Practice

1. The Foundation practices comply with all applicable laws and regulations regarding employment and working life. The employees of the Foundation fulfill all legal requirements within the scope of their activities and act in accordance with the legal regulations.

2. Foundation's human resources policies and practices; recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. it ensures that all other applications are fair.

3.It is unacceptable to discriminate among the employees due to language, race, color, gender, political thought, belief, religion, sect, age, physical disability and similar reasons.

4. A positive and harmonious working environment is created by supporting the cooperation in the foundation and the conflict environments are prevented so that people with different beliefs, thoughts and opinions work in harmony.

5. Employees' privacy and personal areas are respected.

• Communications between persons cannot be violated by non-parties.
• It is forbidden to give / disseminate / seize personal data unlawfully, even if recorded in accordance with law.
• Employee's personal information arising from the nature of the business relationship in the workplaces and which may be required in the future shall not be used for purposes other than their purpose and shall not be shared with third parties without the consent of the persons.
• Private and family life of all employees is respected.

6. In addition to all kinds of immunity of employees, physical, sexual and emotional immunities are also considered.

• Any violation of the immunity of employees by physical, sexual and / or emotional harassment in the workplace or in any other place of employment is contrary to the law and the code of ethics and is not tolerated by the Foundation in any way. The purpose of this practice is to ensure that employees work in a work environment where physical, sexual and emotional immunity is protected.
• Violation of a person's body immunity by sexual behavior and / or sexual harassment of a person without physical contact is defined as sexual harassment. According to this; any behavior that may be considered within this definition is prohibited.
• There is no toleration for the people who act negatively against the people who complain or notify a violation or help during an investigation.

7. No employee may demand privileged treatment, discriminate against anyone due to different sex, religion, language, race or be subjected to a special practice. Making concessions through making use of differences such as gender, religion, language and race cannot be accepted.

8. Workplace physical working environment and conditions are ensured to be healthy and safe for all employees.

III. THE RESPONSIBILITIES OF EMPLOYEES

Policies and procedures related to the foundation, rules on how to behave and how to do our work are defined in detail. Compliance with these rules is the primary responsibility of all employees. Accordingly all employees are responsible to;

• Act in accordance with laws and regulations in all circumstances
• Read documents, ethical rules, know, understand, internalize and act in accordance with the rules, principles and values ​​of Yücel Culture Foundation,
• Learn the general and specific policies and procedures that apply to the Foundation
• Consult with the manager about potential violations related to himself or others
• Promptly report possible violations of himself or others; forward orally or in writing to the manager, human resources and / or the Ethics Committee
• To follow the "Ethical Ways and Methods to be Decided in Terms of Ethics" which is defined to help to act in accordance with the rules and to solve problems
• To cooperate with the Ethics Committee in ethical investigations and to keep the information about the investigation confidential.

A.  Ways and Methods of Ethical Decision Making

As a guide in deciding an action plan, you should follow these steps and ask yourself these questions:

1. Determining Event, Decision or Problem

• Have you been asked to do something that you think it may be wrong?
• Are you aware of a situation in the foundation or our business partners that may be potentially unlawful or that does not comply with business ethics?
• Are you trying to make a decision and do you have doubts about how to behave in accordance with the ethics of doing business?

2. Think Before You  Decide

• Try to explain the problem clearly and summarize
• Ask yourself the reason of contradiction
• Think about the options and results
• Think about the people who might be affected
• Consult others

3. Decide An Action Plan

• State your responsibilities
• Review all relevant facts and information
• Consult appropriate Foundation policies, procedures, and professional standards
• Assess risks and think about how you can reduce them
• Try to create the best action plan
• Consult others

4. Test Your Decision

• Review all the questions which must be asked ethically
• Review your decisions based on the Foundation's core values
• Be sure to consider foundation policies, laws and professional standards
• Consult others and evaluate their views within the planned action plan

5. Continue Resolutely

• Share your decision with your justification with the people concerned
• Share what you have learned
• Share your success stories with others

B. 4 Basic Questions to Consider

1. Does this activity comply with laws, rules and customs? (Standards)

• Does it meet professional standards?
• Is it legal?

            2.  Is this activity / behavior balanced and fair? Would we be bothered if someone else did? (Sense of justice)

• Is it right for you?

            3. Would our foundation and stakeholders feel uncomfortable if all the details of this event were heard by the public? (Emotions and ethical values)

• Would you be embarrassed or find yourself in a difficult situation if others knew you were doing this?
• Might it have negative consequences for you or our Foundation?
• Who else can be affected (other employees within the Foundation, you, Trustees, etc.)?

            4.  To what extent does "reality to be perceived" coincide with "objective reality"?

• How would it be reflected in the newspapers?
•  What would a reasonable person think under the same conditions?

IV. THE RESPONSIBILITIES OF EXECUTIVES

The executives of the Yücel Cultural Foundation have additional responsibilities beyond the defined responsibilities for the employees. Accordingly, the executives are responsible for;

• Ensuring the creation and maintenance of a foundation culture and work environment that supports ethical rules,
• Being an example to the implementation of the code of conduct with its behavior, training its employees about the code of ethics
• Supporting employees in communicating their questions, complaints and notifications regarding ethical rules
• Providing guidance on what to do when consulted, taking into account all notifications and, when deemed necessary, forwarding them to the Ethics Committee as soon as possible
• Ensuring that the business processes under its responsibility are structured in such a way as to minimize the risks related to ethical issues and to apply the necessary methods and approaches to ensure compliance with ethical rules.

V. RESPONSIBILITIES OF ETHICAL RULE CONSULTANTS

Ethical Rule Consultants are responsible for;

• Guiding and advising on questions and issues about ethics raised by employees within the Foundation,
• Referring nonconformities that cannot be resolved within the Foundation or requiring an investigation to the Ethics Committee,
• To contribute to the resolution of the ethical nonconformities by the Ethics Committee's demand,
• Reporting to the Ethics Committee on a regular basis or upon request,
• Being a contact person from the company in the investigations conducted by the Ethics Committee and providing the necessary support to the investigations,
• Monitoring and following the effectiveness of ethical practices carried out at the foundation; supporting for applications.

VI. OTHER RESPONSIBILITIES

• Board of Directors; They are responsible for the effective implementation of the Code of Business Ethics and the creation of a culture in which it is supported.
• Foundation's Human Resources are responsible for;
  • Providing trainings in certain periods in order to inform the employees about the Code of Ethics, to ensure the understanding of the policies and rules, and to ensure the continuous communication of this issue with the employees,
  • Ensuring that the employees of the Foundation read the code of ethics, that they are informed and that they sign the Employee Declaration
  • Ensuring that all employees renew their notifications by signing the Business Ethics Compliance Form at the beginning of each year.
• With the cooperation of Ethics Committee, Executive of Foundation is responsible for;
  • Ensuring the confidentiality of complaints and notifications made within the framework of the Code of Ethics and protecting individuals after their notifications,
  • Ensuring the safety of employees who report
  • Ensuring timely, fair, consistent and sensitive investigation of complaints and notifications, and decisively taking necessary actions as a result of violations

VII. RESOLUTION OF COMPLIANCE WITH ETHICAL RULES

Those who violate the Code of Business Ethics or the policies and procedures of the Foundation will be subject to various disciplinary sanctions, if necessary, to the extent that they are required to leave. Disciplinary sanctions will also apply to those who approve, direct or act on the offending behavior and violations of the rules or who do not make the necessary notification properly.

A. Ethics Committee

The Ethics Committee is responsible for investigating and resolving complaints and notifications that the Code of Ethics has been violated under the Yücel Culture Foundation Code of Business Ethics. The Ethics Committee, which reports to the Chairman of the Board of Directors of the Yücel Culture Foundation, consists of the following positions:

Chairman - Head of Audit Department

Member - Yücel Culture Foundation Member of the Board responsible for legal affairs

B. Ethics Committee Work Principles

The Ethics Committee conducts its activities within the framework of the following principles:

• People who report and complain are kept confidential with the reports and complaints.
• The investigation is as confidentially as possible.
• They have the authority to request information, documents and evidence directly related to the investigation from the unit available. They can review any information and documents obtained only by the subject of the investigation.
• The investigation process shall be recorded in writing from the beginning. Information evidence and documents are added to the records.
• Record is signed by the chairman and the member.
• The investigation is dealt with promptly and the result is reached as quickly as possible.
• Decisions taken by the Board shall be implemented immediately.
• The relevant departments and authorities are informed about the result.
• The chairman and the member of the Board shall act independently and unaffected by the department managers and the hierarchy within the organization while performing their duties on this matter. No pressure or suggestion can be given to them.
• The Board may seek expert opinion if it deems necessary and may benefit from the experts by taking measures that will not violate the confidentiality principles during the investigation.

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