1. The Purpose

The purpose of Anti-Bribery and Anti- Corruption Policy is to put forward policies fighting against bribery and corruption. 

2. Scope

This policy covers and is applicable on;

This policy is an integral part of;

3. Definitions

Corruption is the misuse of the authority held due to the position for the purpose of gaining advantage directly or indirectly. 

Bribery is a person's gaining advantage or providing advantage to others within the framework of an agreement reached with a third person so that such person acts in breach of the requirements of his/her duty by doing or not doing a work, speeding up or slowing down thereof, etc.

4. Duties and Responsibilities

Implementation and updating of the Anti-Bribery and Anti-Corruption Policy are in the responsibility and duties of the Board of Directors. In this context, the followings are required:

Moreover all Yücel Culture Foundation employees are responsible for;

5. The Companies from/to Which Good and Services are Bought and Sold and Business Partners

The companies from which goods and services are bought and to whom goods and services are sold and Business Partners must comply with the Policy principles and other relevant regulations. Relations with persons and institutions failing to comply these conditions shall be terminated. In addition to criteria such as experience, financial performance and technical sufficiency, The Executive Board takes into account morality and a positive background in this field during the selection of the companies from which goods and services are bought and to whom goods and services are sold and the Business Partners. The companies and the Business Partners which have a negative information with regard to bribery or corruption are not collaborated even if they meet other requirements. Responsibility for making necessary research and evaluation within this scope primarily belongs to the Executive Board. Internal Audit Department evaluates in its controls whether such issues are complied with.

6. Our Policies and Procedures

6.1 Bribery and Corruption

6.2    Gift

6.2.1  Gifts From Suppliers, Service Providers or Other Business Partners

- If it is frequent (once or twice a year for each partner),

- Each year and each person/company who gives gift being separated, the total cost of gifts must be lower than 250 Turkish Liras,

- If it is housing for business or it is based on common business practices,

- If it does not violate the law or regulations,

- If there is no probable or potential affect on the decision about the contract the Supplier depends on after the relevant gift or housing is accepted.

- Promotion gifts (such as pen, calendar, notebook, coffee cup, shirt or other basic outfits) and mostly the gifts with no economic value.

- As long as the invitation is for business purpose (such as in the scope of a business meeting) and the cost of business meal is suitable for the position in Yücel Culture Foundation of the person invited, it is allowed to invite for a meal occasionally,

- It is prohibited to affect the person by giving gifts, help or invitation during these meetings. (such as a gift, help or invitation and ordering something or any relation shaped in the process of tender.)

- If there is a direct business goal (not directly related to the existent business contract)

- If the employee is accompanied by someone who has a business relationship with.

- If the cost of the ticket is suitable for the invited person's position in his country. Acceptance of such an offer is subjected to the superior's approval. In addition to the rejection of the invitation of spouses or friends, the inviting company must be refused to cover travel or accommodation costs.

6.2.2 Gifts to Government Authorities and Government Officials

The rules set out in Section 6.2.1 also apply to the public authorities, government officials and third parties associated with them. Employees of the Foundation should refrain from a promotional gift to a government official that will affect the decisions of a person in the performance of their official duties. For this reason, all employees are prohibited from taking any action or taking any measures that may be subject to this pressure. It is in principle prohibited to give, offer, promise or authorize money or equivalents or gifts, aid or donations to any government or government officials.Exceptions are subject to prior approval of the Foundation official and the ethical representative. Invitations to regular business lunches for civil servants require prior approval from the employee's supervisor. Making payments or securing non-cash equivalents, invitations, gifts, donations or grants (also known as acceleration payments) is always prohibited in order to secure or expedite the routine procedures of government officials or private sector employees.

6.3. Personnel Rotation and Internal Audit

7. Correct Recording

Issues which Yücel Culture Foundation must comply with in relation to accounting and recording system are regulated with legal regulations. Accordingly;

8. Appointment of Representatives and Consultants

Rules prohibiting bribes to employees of business partners or public organizations cannot be avoided by appointing representatives or consultants. The contractor's and consultant's contracts may be subject to review in internationally relevant country legislation.

In order to ensure that representative and advisory contracts have a legitimate business purpose, attention should be paid to the following:

9. Training

10. Notification of Policy Breaches

11. Policy Breaches

12. Enforcement

This policy was put into practice with the decision of Yücel Culture Foundation's Board of Directors dated 23.07.2019 and numbered 175 and the Board of Directors is responsible for its execution.

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