Purpose

Şef Sarım San. Ve Tic. Ltd. Şti (hereinafter referred to as Şef Sarım) aims to clearly declare its approach against bribery and corruption, to protect the corporate image and to comply with legislative regulations, ethical and professional codes of ethics laws against bribery and corruption with this policy.

It has also aimed to make necessary communication to prevent bribery and corruption within all the company activities and to describe responsibilities and rules in this regard.

Scope

Fight Against Bribery and Corruption Policy does not only comprise Şef Sarım employees but is also related to all partners that provide service to Şef Sarım.

In this direction;

  • All company employees,
  • Service supplier companies such as consultancy, attorney, etc. and their employees,
  • Outsource service companies (supplier, vendor, etc.) and their employees,

are in the scope of the policy.

Descriptions

Bribery: It defines that a person himself or the one pointed by him gets material or moral, directly or indirectly benefit from another party within scope of a contract or verbally in order to implement an activity outside the ordinary job flow or sake of duty such as doing or not doing a job, speeding up and slowing down. The bribe can be in many ways such as cash money, gift, event invitation or ticket, debt forgiveness, grant in aid.

Corruption: It defines misconduct of authorization arising from the position by using direct or indirect ways in order to get personal material or moral benefit.

Authority and Responsibilities

Top Management is responsible for building up the Fight against Bribery and Corruption Policy, implementation and updating.

Managers should ensure that the principles in this policy document are well understood, implemented and sustained by their partners and their personnel.

All employees and partners should act in compliance with this policy document. Employees and partners cannot be forced to act contrary to this policy in any case and by anybody.

Everybody is responsible to report any breach of the rule regarding fight against bribery and corruption.

Policy

Şef Sarım has the principle to conform laws and regulations, universal laws, ethical and occupational principles in all countries that it is active and represented.

According to this principle, it undertakes to continue its activities in a fair, honest and legal way with the “zero tolerance” against the bribe and corruption approach.

Even if it is in favor of Şef Sarım, it is forbidden to make a payment or offer anything valuable for getting a benefit that is not legal or ethic, get similar benefit from other corporates or person, be in any act that can be evaluated as illegal or non-ethic in its activity countries or business even this kind of applications are common there.

It is not important whether any action is taken or not against the value of benefit subject to bribe and corruption. Even if the benefit value is small or the promise given is not realized yet, this is also defined as a wrongful act against Fight against Bribe and Corruption Policy.

Employees and partners receive training and awareness educations regarding fight against bribe and corruption programs and legal necessities. Secure and accessible communication channels are provided for employees to report suspicious cases. Any payment to ease or speed up any kind of job is forbidden. Employees should not show tolerance and allow third parties to propose, promise, ask for, demand or give these in their relations. In case necessary approvals are not provided (specific for gift/hospitality level or in general), it is not allowed to give a gift, accommodate or offer any other type of benefits directly or indirectly to either foreign or native, to officeholder or state officials.

It is not important whether any action is taken or not against the value of benefit subject to bribe and corruption. Even if the benefit value is small or the promise given is not realized yet, this is also defined as a wrongful act against Fight against Bribe and Corruption Policy.

Witnessing or Getting Suspicious about Bribe and Corruption

All Şef Sarım employees are responsible to report bribe and corruption they witness or suspicious subjects to their managers without losing time. Some examples of these cases are as follows:

– Offering bribe to you or to your colleagues

– Benefits or conflict of interests you witness or you know

– Irregularities that you get aware in company documents

– Acts and behaviors such as favoritism or benefiting you witness in tenders or procurements

– Any person or establishment either inside or outside the company forcing you or your colleagues to act contrary to the policy document

Sanctions Against Improper Actions and Attitudes

Fight against Bribe and Corruption Policy should be adopted and applied by the employees.

It should be remembered that in case of breach of Fight against Bribe and Corruption Policy, sanctions may be applied including cancellation of labor contract and in most of the countries, this kind of breach has important sentences including prison.

Training and Review

Related parties are trained regarding the fight against bribe and corruption and adopting the basics of this policy. The policy is reviewed on a regular basis, necessary updates are made and all changes are announced by notice. Updated versions of these laws are consistently and easily accessible on server.