1.INTRODUCTION

Principles define the expectations from employees regardless of their identity, history and working place.

Ethical Principles are adopted in order to define the standards which Şef Sarım San. ve Tic. Ltd. Şti. (hereinafter referred to as Şef Sarım) employees are responsible to act in compliance with.

Standards are based on the following core values: • Human rights that are accepted internationally • Ethical and legal behaviors • Fair, polite and respectful behaviors of employees • Professionalism

These rules are effective for all levels of management and employees in Şef Sarım. All employees should comply with the rules and they should refer to these rules while acting on behalf of Şef Sarım. This policy is prepared to define the frame of basic ethic rules that Şef Sarım employees should comply with and it is aimed to be a guide for them to make decisions and behaviors while implementing their responsibilities. Employees are expected to act in compliance with common sense behavior within the public morality principles. This policy can always be updated and changed. Şef Sarım is always open to change suggestions from employees.

2.OUR JOB PRINCIPLES

The most valuable possession of Şef Sarım is its respected image and corporate brand built by the result of activities during its long history. Basic job principles that all employees are obliged to comply with within their activities in order to protect and improve Şef Sarım’s corporate image are given below. Şef Sarım expects all its employees to act by understanding and adopting Company values and ethic principles during their operations.

2.1. Honesty

In all its activities Şef Sarım considers honesty, transparency, and high job ethic values above all and expects all parties cooperating to act in the same manner conforming to the same values.

Şef Sarım, one of Turkey’s reliable and respected companies, never acts in a particular manner of losing trust in business relations against its partners, employees, suppliers, competitors, environment, society, and humanity.

2.2. Confidentiality

Confidential information is subjects such as information owned by the company and not known by third parties, information that can harm company and/or partners or can benefit third parties in case of disclosure, all kinds of financial, strategic, technical, commercial information and subjects constructed in privacy agreements with third parties and similar information. Şef Sarım expects its employees to show due care to protect all information owned by Şef Sarım and its partners. Employees share such information only with authorized related persons. Confidential information is not shared with third parties while being taken out of Şef Sarım. Employees are obliged to deliver all kinds of the document or soft copy documents owned by Şef Sarım and kept during their working period. Our new employees in Şef Sarım cannot share confidential information of their previous employers in Şef Sarım as well. Şef Sarım expects its employees to protect all agreements, such information, and documentation, and confidentiality of information which are referred to as Şef Sarım’s secret financial information, commercial secrets, information and documentation regarding employee rights or agreements that are made with business partners and can weaken Şef Sarım’s competition power. Şef Sarım employees are expected to avoid sharing or using for speculative purposes (directly or indirectly) of obtained or possessed information with unauthorized persons and authorizations inside or outside the company.

2.3. Fair Work Environment

Şef Sarım believes in and supports people’s rights and freedom in all its operating regions. In this direction, Şef Sarım does not make discrimination under no circumstance regarding people’s ethnic origin, gender, race, nationality, economic condition, religion, and other beliefs. This condition is valid during employment and promotion, for provided working conditions, for all relations with the customers and suppliers. Şef Sarım is obliged to ensure that the work environment, products, and services are in compliance with human health and safety. Each employee has the right to be treated fair, polite and respectfully by his/her inferior, manager and colleague. Employees’ performance, development, and engagement will be increased in an environment where employees are respected and all legal regulations are followed by building a healthy and safe working environment.

2.4. Compliance with Laws

Şef Sarım is obliged to comply with national laws. Employees are not allowed to violate the laws with the thought that they service the company or their self-interest.

2.5. Human Resources

Şef Sarım’s necessary basic principles in order to maintain quality human resources management are summarized below:

  • • Favors cooperation between employees in a work environment.
  • • While recruiting and promoting employees considers the qualifications and skills required by the job.
  • • Assigns employees in positions that they can use their potentials, add value and contribute to Company targets.
  • • Provides employees fully use their personal rights.
  • • Creates training and development opportunities, within the scope of human resources, to improve themselves in the best manner and do their job better.

2.6. Quality, Environment, Occupational Health Safety and Continuous Development

  • • According to management by objectives philosophy, risks and environmental impacts of our activities, we have built and have been applying an integrated management system for Quality, Environment, Occupational Health and Safety subjects in order to avoid pollution, injury and health impairment.
  • • Our policy is to increase our customer and employee satisfaction by meeting Quality, Environment, Occupational Health, and Safety standard needs in order to achieve our goals.
  • Our basic principle is to satisfy our customers’ fair price, quality production and delivery on time expectations with care, attentive and minimum fault by using the best quality products of world brands.

2.7. Public Activities

• Şef Sarım establishes its relationship with state organizations and institutions in the frame of ethical principles in accordance with laws and regulations.

3.EXTERNAL RELATIONS WITHIN ŞEF SARIM

Following basic principles guides Şef Sarım’s relations with its partners:

3.1. Relations with State Organizations

  • • To act in compliance with the legislation in the countries that the business relations are ongoing or planned to be carried out.
  • • Directing, recording and reporting. the business and accounting systems in accordance with laws.

3.2. Social Responsibility

  • • To support the efforts that contribute to economic and social development,
  • • To be sensitive to the subjects related to society and to support improvement efforts.

3.3. Customer Relations

  • • To add value for customers, fulfill their needs and demands at the highest level,
  • • To produce quality product and service,
  • • To create long-term-trust type relation in our customer relations,
  • • To increase sales and aftersales customer satisfaction and aim to be the preferred brand in the eyes of customers,
  • • Avoid giving deceptive or imperfect information to customers.

3.4. Supplier Relations

  • • To make common action while adding value in supplier business relations,
  • • To build an open, direct and honest relationship with suppliers,

3.5. Competitor Relations and Competition

  • • Except that it is allowed by the law, to avoid behaviors which block competition directly or indirectly, aiming to limit other persons’ or companies’ competition power,
  • • To avoid information exchange or building discussion platforms with competitors to form competitive conditions.

4.RESPONSIBILITIES OF THE EMPLOYEES

The primary responsibility of Şef Sarım employees is to ensure that the name “Şef Sarım” is synonymous with professionalism, integrity, and honesty and also carry it to the next level. In this context, the following behaviors are expected from Şef Sarım’s employees:

  • • To always obey the laws,
  • • To do their jobs and operation within the authorization assigned them and ask their managers for the subjects exceeding their authority,
  • • To fulfill their tasks within the frame of basic moral and human values,
  • • To behave fair, kind and sympathetic in relationships for common interest,
  • • To avoid getting or giving bribe from any person or any organization under any circumstances,
  • • To act in compliance with all principles and applications supporting job ethic rules in all operations performed,
  • • To avoid any behavior, declaration or written explanation binding the company without permission,
  • • To avoid behaviors that disturb or harm other employees or damage workplace harmony,
  • • To protect all assets of the company from damage, abuse, theft, and sabotage including the company’s documentation and information systems,
  • • To avoid getting personal gain directly or indirectly in working hours and using company resources.

4.1. Asset and Information Management

4.1.1. Using the Company Resources

Comprehensive Şef Sarım Policies related to use of company resources are explained below:

4.1.1.1. Internet and Electronic Mail Policy
  • • Employees should use internet access and email send/receive functions only for business purpose,
  • • Internet access and email system of Şef Sarım is a company resource and Şef Sarım has the right to follow, monitor, and copy the internet usage and emails,
  • • Employees should take adequate care to avoid disclosure of confidential information and obtain illegal information.
4.1.1.2. Conformity to Information Technologies Policies

Employees are always obliged to comply with Information System policies. Below-mentioned policies are as follows:

  • • Not to use unlicensed software,
  • • Not to make compromises regarding connection security,
  • • Not use or download the content of adult, gambling&betting, harmful and illegal web sites.
4.1.1.3. Equipment and Device

Office equipment, office furniture, fax machines, computers, software, hardware, devices, and similar equipment belong to Şef Sarım and cannot be used for personal purposes.

4.1.1.4. Personal Affairs

Şef Sarım employees cannot use Şef Sarım resources for their personal affairs.

4.1.2. Information Management

  • • To ensure that all records required legally are kept,
  • • To avoid answering the confidential information requests of third parties regarding company operations without the approval of top management.

4.1.3. Safety and Crisis Management

  • • To take necessary precautions to protect employees, information and documentation systems against natural disasters,
  • • To take all personal precautions to avoid theft or loss of company assets.

4.2. Avoiding from Conflict of Interest

Conflict of interest is defined as a possible interest that prevents employees to implement their job impartially and conflict of interests of employee’s family, friends and other people or corporates he/she has a relation with the company’s interests.

Şef Sarım expects its employees to avoid possible conflict conditions of conflict of interest and inform his/her manager immediately in such cases.

4.2.1. Avoiding from Related Party or Self Interest Operations

  • • To avoid using the advantage of his/her position or power, third parties, related parties or derive improper personal benefit for anybody,
  • • To avoid getting into a conflict of interest for undertaken job,
  • • To avoid from occupying other employees’ time or distracting their attention, making their concentrations to work difficult during the implementation of the work,
  • • Informing the related manager immediately in case the employee is first degree relative of customer or supplier who is a decision-maker in the same sector,
  • Çalışanlar, başka bir şirkette ya da yatırımda hissedar olduklarında, bunu açıklamaları gerekmektedir. Çalışanların, çıkar çatışması olarak algılanabilecek bu bağlamdaki ya da benzer özellikteki herhangi statü değişikliklerini acilen en az iki üst seviyedeki müdürlerine bildirmeleri gerekmektedir.

4.2.2. Receiving and Giving Present

When entering into relation with persons or corporates who have the intention to have a relationship or continue their relationships with Şef Sarım:

  • • Avoid receiving or giving any gift/activity which can violate free-thinking and decision-making atmosphere except for the presents and related activities of the business tradition, general culture, and customs.
  • • Avoid requesting discounts or material which can be considered as inconvenient, proposing the same to third parties or accepting if it is proposed from suppliers, customers or third parties except that it is within the frame of commercial precedent.

4.2.3. Information Leakage

Employees should avoid transferring Şef Sarım’s any kind of confidential information to third parties. Employees violating this article shall be directly responsible for the results of their acts. Employees should be aware that confidential information trade is an illegal violation. Besides, the wrongful act against this article arises breach of employee’s labor contract and should not take place under any circumstance.

4.3. Records and Documents

4.3.1. True and Complete Job Files

Employees should act in good faith while using communication channels of Şef Sarım’s record and documentation, internal and external relations or any including phone or electronic communication devices in order to prevent inaccurate information.

4.3.2. Financial Reporting

All Şef Sarım resources, assets, obligations and documents are recorded according to relevant legislation provisions and generally accepted accounting standards.

4.3.3. Cooperation with Auditors

Şef Sarım employees should cooperate with internal and external auditors during the inspection of the corporate book, records, and activities.

5.RESPONSIBILITY OF THE MANAGERS

Şef Sarım managers have additional responsibilities besides their described responsibilities. These are:

  • • To build up and protect the working environment and corporate culture that support the ethic principles,
  • • To serve as a model while applying the ethic principles, to train the personnel about ethic principles,
  • • To support the employees’ questions and express their complaints/concerns regarding the ethic principles,
  • • To guide when they are asked about any ethic principle subject,
  • • To structure the business processes to minimize the ethic risks and apply the necessary methods and approaches to ensure that the ethic principles are conformed.

6.OTHER RESPONSIBILITIES

  • • Board of Management is responsible for effective application and support of Şef Sarım ethic rules or thus created Business Ethics rules specific to the company.
  • • All policies regarding Ethics Principles are reviewed, revised and documented by Management Systems and Offer Preparation Officer upon Board of Management’s suggestion and revisions are announced in Şef Sarım after Board’s approval.

7.VIOLATING THE ETHICAL RULES

Those who violate business ethic principles and/or company policies and procedures may be subject to a disciplinary proceeding that leads to the cancellation of labor contracts. The disciplinary proceeding is also applied to those who do not report violation although they are aware of it, who does not start the necessary process and who approve the acts that violate the ethic principles or their managers. Non-Retaliation Policy: Employees in goodwill cannot be exposed to retaliation because they report ethic policy violation suspicion or realized violation. Retaliation is a very serious Ethic Principle violation and should be reported immediately.

8.ZERO-TOLERANCE POLICY AGAINST VIOLATION OF RULES

Şef Sarım adopts a zero-tolerance approach against ethical principle violation, incorrect reporting of principle violation and retaliation against who reports the principle violation. Şef Sarım can apply disciplinary proceeding provisions against employees who retaliate the ones that reports the violators.