Ethical Values and Codes of Conduct Procedure

1.0 PURPOSE AND SCOPE: The purpose of this procedure is to reflect the corporate values and general principles that guide ALPIN KIMYA and our activities that are a part of it. This procedure covers all ALPIN KIMYA employees.

2.0 RESPONSIBLE: All Managers and employees are responsible for the implementation of this procedure.


3.1. Our Values

We are committed to creating a reliable, healthy and fair working environment without any discrimination by ensuring that our employees fully and correctly use all their rights.

  • We provide suitable conditions for our employees to work in a safe and healthy environment by minimizing the danger in work areas.
  • We raise awareness of them by regularly training them for their health and safety.
  • We plan working hours and leave days fairly, taking into account the personal rights of our employees. We do not employ them under any circumstances that compel them.
  • Under no circumstances, religion, language, color, gender, political opinion, age and physical disability etc. among employees within the organization. reasons cannot be discriminated against and those who do cannot be ignored.
  • Freedom of employees cannot be restricted, we respect their thoughts and opinions and ensure that they work in a harmonious environment.
  • We do not employ child labor in our factory. We undertake not to work our young workers (interns) without exceeding their working hours or in dangerous conditions.
  • Employee and management representatives listen to the requests and complaints of all employees and report them to the management. Complaints are terminated by finding solution methods for necessary issues.

3.2. Ethical Values and Code of Conduct

The above-mentioned corporate values should constitute a reference that guides the behavior of all ALPİN KİMYA employees.

At the core of the code are mutual respect between people who are in contact with each other, commitment to the company and its work, responsibility to do its job in the best possible way, solidarity and cooperation with the community and colleagues, honesty and respect for the law. With the implementation of these principles, our working environment will be a safe space free from aggression, all kinds of abuse, intimidation, harassment and discrimination, allowing for personal and professional development.

Naturally, these principles cannot cover all the daily situations that may be encountered during working life, but they can determine the minimum rules that will guide the employees during their professional activities.

Compliance with the content of this Code is mandatory for everyone working within ALPİN KİMYA.

All of our employees are expected to exhibit attitudes and behaviors that will ensure the cultural integrity of our company, and to protect and develop the reputation of our Company and the reliability of its corporate structure. All employees, including temporary employees, are obliged to comply with the Code of Ethical Conduct.

All stakeholders are expected to abide by the rules of business ethics and all implementation principles that support these rules.

Notifying all employees of the Code of Ethical Conduct, ensuring that employees attach the necessary importance to these rules, and showing the necessary effort and leadership in complying with the Code of Ethical Conduct are among the main duties and responsibilities of employees in the management role.

The latest version of the Code of Ethical Conduct and Implementation Principles document has been read, understood and understood by the employee, and

The responsibility to document the commitment to implementation rests with the Administrative Affairs and Human Resources Manager.

3.3. Employee Relations

  • ALPİN KİMYA, consisting of the most successful and competent professionals who create the added value that will ensure sustainable growth,
  •   aims to be the most preferred and ideal institution that everyone is proud to be a part of.
  • ALPİN KİMYA values its employees and respects employee rights. In this context; The only measure in hiring and employment
  •   to seek the qualification of suitability for the job, to provide equality of opportunity without discrimination,
  • Bringing the most qualified young people and experienced professionals who will take our company forward,
  • To provide maximum benefit from the talents, power and creativity of the employees,
  • To provide opportunity and equality of opportunity for the training, orientation and development of employees,
  • Achieve success with fair and competitive wage policies, effective and objective performance evaluation systems and practices. reward,
  • To ensure the continuity of labor peace,
  • To provide employees with clean, healthy and safe working conditions in every aspect, where necessary occupational safety measures are taken,
  • To create and perpetuate a working environment that is transparent and encourages mutual respect, where cooperation and solidarity are the most important elements,
  • Not to allow harassment in the workplace in any way,
  • Evaluating and responding to the opinions and suggestions of the employees and taking motivation-enhancing measures,
  • Not to share private information about employees with third parties without the employee's permission and knowledge, except for legal obligations,
  • Respecting human rights constitutes the basic principles in terms of relations with employees.

3.4. External Relations

The basic principles that guide the relations of ALPİN KİMYA with its stakeholders are listed below:

3.4.1. Communication with Stakeholders

Representing ALPİN KİMYA before the society and increasing its reputation,

Keeping communication channels open with stakeholders, benefiting from their criticisms and suggestions, ensuring the continuation of positive relations,

Avoiding personal opinions in sharing opinions with the public.

3.4.2. Shareholder Relations

To protect the rights and interests of its shareholders as determined by law,

To show maximum effort to create value in return for the resources provided by its shareholders,

Ensuring that the matters that need to be disclosed regarding the companies are announced fully, timely and accurately to the shareholders and the public,

To ensure that our company is managed within the framework of the principles of ongoing trust and honesty, to target sustainable growth and profitability.

to manage its resources, assets and working time with efficiency awareness.

3.4.3. Government Relations

  • To comply with all laws, rules and regulations regarding customers in countries of operation and new entry.
  • To manage, record, and fully manage all business activities and accounting system in accordance with the law to report.

3.4.4. Social responsibility

Supporting studies that will contribute to economic and social development,

To show sensitivity to the issues that concern the society and to support the positive development of the society,

3.4.5. Customer relationship

Creating value for customers, meeting their demands and needs at the highest level,

To provide quality products and services and to follow stable policies, always taking into account customer special requests,

Creating a long-term trust environment in relations with customers,

Aiming to be the first choice by increasing customer satisfaction in the sales and after-sales process,

Not to give misleading and incomplete information to customers.

3.4.6. Supplier Relations

  • Creating mutual value in business relations with suppliers,
  • To carry out communication with suppliers in an open, direct and correct manner,
  • To decide with objective criteria in the selection of the supplier,
  • To comply with reasonable confidentiality and occupational safety rules requested by the supplier during supplier inspections and visits.

3.4.7. Competitor and Competition Relations

Not to enter into agreements and harmonious behaviors with competitors or other persons or organizations that aim to prevent, distort or restrict competition directly or indirectly, or that have or may cause such an effect, outside the limits permitted by the legislation,

  • Not to abuse this dominant position in cases where it is in a dominant position alone or together with other undertakings,
  • Not negotiating and exchanging information with competitors to determine the market and/or competition conditions together,
  • Associations, councils, chambers, professional associations, etc., which represent the Company. To avoid all kinds of meetings and transactions that may lead to the above-mentioned situations or be described as such in meetings and other private or professional meetings and negotiations.

3.4.8. Global Responsibility

To develop environmental policies and ensure their effective implementation,

To act for the benefit of our country and the world in accordance with the principles of environmental legislation, to show an example of corporate citizenship with our employees and suppliers.

3.4.9. Responsibility for not using counterfeit parts

Alpin Kimya maintains traceability of purchases from Suppliers, retaining the original purchase orders and other receiving documentation, including manufacturers’ Certificate of Conformance, for the required document retention periods.

Alpin Kimya preserves the traceability of the purchases made from the Suppliers by keeping the original purchase orders and other purchasing documents including the Certificate of Conformity of the manufacturers during the required document retention periods.

3.4.10.Responsibility for Export Controls and Economic Sanctions

When to our businesses, it is one applicable of the main principles of the Company to fully comply with the economic sanctions administered by: the Republic of Turkey, the European Union (the ""EU""), (respectively, “Turkey Sanctions”, and the “EU Sanctions”) as well as the economic sanctions and export controls administered by other jurisdictions, (collectively, the ""Sanctions"").

3.4.11 Responsibility for Whistleblowing and protection against retaliation

A whistleblower as defined by this policy is an employee of Alpin Kimya who reports an activity that he/she considers to be illegal or dishonest to one or more of the parties specified in this Policy. the whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Examples of illegal or dishonest activities are violations of laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.

3.5. Ethical Rules of Conduct for Employees

It is the primary responsibility of all its employees to continue to be remembered with professionalism, honesty and trust and to move it forward. In this context, the expectations from ALPİN KİMYA employees are listed below:

Always comply with the law,

To fulfill their duties within the framework of basic moral and human values,

To act in a fair, well-intentioned and understanding manner in order to provide mutual benefit in all relations,

Not to gain unfair advantage from individuals and organizations for any reason, not to take or give bribes,

To act in accordance with the + business ethics rules and all application principles that support these rules, in the ongoing duties,

Not to make any behavior, statement or correspondence that will make ALPİN KİMYA commit, unless expressly authorized,

Not to engage in behaviors that will disturb and/or harm other employees, not to disrupt work harmony,

To take care of all tangible and intangible assets of ALPİN KİMYA, including information and information systems, as if they were personal property, to protect them against possible loss, damage, misuse, abuse, theft and sabotage,

Not to directly or indirectly use working time and company resources for personal and/or political activity and benefit.

3.5.1. Asset and Information Management Intellectual Property Rights

Ensuring that legal transactions are initiated and completed on time in order to secure the intellectual property rights of newly developed products and processes,

Other companies' patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights

knowingly avoiding unauthorized use. Information Management

Ensuring that all legal records are kept in a healthy way,

Not responding to information requests from third parties, which are classified as confidential for the company, without the approval of the senior management,

To show the necessary diligence to ensure that the statements and reports made by ALPİN KİMYA are in accordance with the truth. Security and Crisis Management

To protect company employees, information and information systems, factory against possible terrorism, natural disasters and malicious attempts.

to take the necessary measures,

Terrorism, natural disaster, etc. To make the necessary crisis planning for the emergency crisis management to be created in case of a crisis, and to ensure the continuity of the business with minimum loss in this way,

To take every precaution to prevent ALPIN KIMYA's assets from being stolen or damaged. Security

Company's financial and trade secrets, information that will weaken the competitiveness of the Company, personnel rights and information, business

To act with the awareness that the agreements with its partners are within the framework of ""confidentiality"", to protect and confidentiality of them.

to ensure,

Disclosure of information learned by business and documents they have with unauthorized persons and authorities inside and outside the Company for any purpose.

not to share, not to use directly or indirectly for speculative purposes,

Not to use non-public information about the companies they work with and their customers and other people and companies with which they work for purposes other than the foreseen purpose, and not to share them with third parties without obtaining the necessary permissions.

3.5.2. Avoiding Conflict of Interest

conflict of interest; means all kinds of benefits provided to themselves, their relatives, friends or the persons or organizations with which they have a relationship and having any material or personal interest related to them, which affects or may affect the impartial performance of their duties. Not to act in favor of himself or his relatives

Employees are required to notify the situation of owning shares in another company or participating in their investments, if any, at the time of their first employment. Employees report changes that may occur over time and similar issues that may be perceived as conflicts of interest to their superiors.

Not to gain unfair advantage in favor of himself, his relatives or third parties by making use of his title and authority,

To take care not to have a conflict of interest with the current company in personal investments to be made,

Taking care that personal investments to be made or occupations other than any business activity do not interfere with the current task in terms of giving time and attention, and to avoid such situations that prevent focusing on main tasks,

Persons who are in the primary decision-making position regarding the same job in the Company, which is the employee and the customer or supplier.

Informing his/her superior in case of a first degree relative,

If it is learned that his relatives have a share or material interest in another company with which he has a commercial relationship inform your superior. Participation in representation and organization invitations

Open to general participation by persons or institutions with whom a business relationship is or has the potential to be; conference, reception, promotional events, seminars, etc. Sports activities outside of the country, which are influential in decision-making or can be perceived as such, domestic / international trips, etc. Participation in invitations is subject to the approval of the General Manager. Giving and Receiving Gifts

In the conduct of relations with private or official persons and organizations that want to establish or maintain a business relationship with the Company;

Not accepting or offering any gift that creates the impression of the existence of an irregularity, that may cause or be perceived as such, other than those given in accordance with commercial traditions, customs, or souvenir / promotional materials,

Not requesting any discounts or benefits that may be perceived as inappropriate from suppliers, customers, Group companies or third parties, not offering them to third parties, not accepting them when offered. Doing business with the Community for layoffs

After leaving his job at ALPİN KİMYA, he established a company himself or became a partner in a company.

Doing business with ALPIN KIMYA as a seller, contractor, consultancy, brokerage, representative, dealership or similar is a very important issue that should be considered as it may create negative perceptions.

Acting in line with the interests of ALPİN KİMYA before or after such a process, compliance with moral and ethical rules.

It is necessary to ensure that conflicts of interest are not allowed before and after the process.

For a supplier in this situation, the relevant manager should contact ALPİN KİMYA, where the supplier worked before, and prepare a report that there is no inappropriate situation and inform his superior.

If there is an inappropriate situation, commercial relations should not be established with the person concerned. Insider Trading

Knowing that it is a legal crime to try to gain any commercial interest (insider trading) by using any confidential information of ALPIN KIMYA or by giving it to third parties, and certainly not to attempt it. Combating Corruption and Bribery

ALPİN KİMYA is an unethical policy aimed at influencing the actions and will of individuals in order to gain advantage.

against applications.

As a result of this, no ALPİN KİMYA employee can gain profit, offer or accept bribes by using third parties working in any public or private organization in order to gain advantage or to perform any business. Even;

should complain about the bribery incident or incidents of which he/she has knowledge, in accordance with the established procedures.

3.6. Worker's health and work safety

Our company has aimed to fully provide occupational health and safety in the workplace and on the job.

Employees act in accordance with the rules and instructions set for this purpose and take the necessary precautions.

Do not dispose of any item or substance that poses a danger to employees, the workplace and/or workers or is illegal in the workplace.

they will not have.

Employees; except those held on the basis of a valid doctor's report; they will not have drugs, addictive, mental or physical abilities restricting or eliminating substances in the workplace, and they will not work in the workplace or within the scope of work while under the influence of such substances.

3.7. Political Activity Ban

Our company does not make donations to political parties, politicians or political candidates. Demonstrations, propaganda and similar activities are not allowed within the boundaries of workplaces on these matters. Company resources (such as vehicles, computers, e-mails) cannot be allocated to political activities.

3.8. Ethical Code of Conduct Implementation Principles

3.8.1. Obligation to Notify Violations

If employees learn or suspect that the Code of Ethical Conduct or the laws and regulations to which the company is subject, they are obliged to report this to their first manager or, as appropriate, to the General Manager.

Disclosure of the person's notification to third parties in a way that will adversely affect the peace in the workplace or business relations is strictly prohibited.

will be avoided.

It should be ensured that the notification mechanism is in the interest of the company.

It is very important that the whistleblower is free from any intentions such as gossiping about the whistleblower or trying to negatively affect his career. In this respect, confidentiality, objectivity and compliance with ethical rules are an extremely critical issue in the reporting and investigation process. It is obligatory for the people who make the notification and who manage the process related to the issue to pay maximum attention to this issue. When false and/or slanderous intentional statements are detected, it is interpreted as a violation of the code of ethics.

8.2. Ethical Conduct Committee

The Ethical Behavior Committee will work to better evaluate inappropriate situations related to ethical rules, to implement disciplinary practices and to ensure parallelism in practices.

The Ethical Behavior Committee consists of the following people:

  • General Manager (Chairman of the Company Ethical Behavior Board)
  • Factory manager
  • Administrative Affairs and Human Resources Manager
  • Legal advisers

8.3. Disciplinary Practice

The following disciplinary penalties are applied after violations of the Code of Ethical Conduct:

If there is an abuse determined to be done knowingly; dismissal in accordance with the relevant articles of the labor law and necessary

If seen, take legal action. (The useful deeds of the person who knowingly provided unfair advantage in the past will not affect the decision taken.)

cannot constitute a reason for amnesty in whole or in part.)

If there is no abuse or negligence due to carelessness or ignorance; verbal or written warning appropriate to the effect of the event

to be done.