Anti-Bribery and Corruption Prevention Procedure

1. Purpose

This policy aims to clearly set out Petaş Ambalaj’s approach to bribery and corruption. As Petaş Ambalaj, this policy aims to ensure compliance with anti-bribery and anti-corruption laws and regulations, legal regulations in the countries of operation and ethical principles, and to determine the responsibilities and rules on this subject.

2. Scope

Our anti-bribery and anti-corruption policy covers;

2.1. Members of the Petaş Ambalaj Board of Directors,
2.2. Petaş Ambalaj managers and employees,
2.3. Our subsidiaries, affiliates and their employees,
2.4. Companies from which we receive external services; persons and organizations acting on behalf of Petaş Ambalaj companies, including consultants, lawyers and external auditors (business partners).

This Policy;

2.5. The Code of Business Ethics and Social Compliance Policy
2.6. is an integral part of the Disciplinary Regulation and Procedure.

3. Definitions

This section briefly explains the special terms and expressions, concepts and abbreviations used in the policy.

3.1. Petaş Ambalaj / Senior Management: The definition indicating the partners’ board (General Manager and deputies).

3.3. Document: Any written text in which Petaş Ambalaj policies, regulations, procedures and business processes have been created in writing and made accessible to the relevant employees.

3.4. Employee: Refers to Petaş Ambalaj personnel.

3.5. Service Provider: Refers to the personnel of the company (supplier, subcontractor, customer etc.) from which and/or to which Petaş Ambalaj receives and/or provides services.

3.6. Corruption: The abuse, directly or indirectly, of a duty or authority held by reason of one’s position for the purpose of obtaining gain.

3.7. Bribery: The provision of a benefit within the framework of an agreement for a person to act contrary to the requirements of their duty by means such as doing, not doing, accelerating or slowing down a task.

3.8. Public Official: As set out in the Turkish Penal Code, covers persons who participate, permanently, for a term or temporarily, in the conduct of a public activity by appointment or election or in any other manner.

“Public”: Means all organs of the state that provide public services.

4. Responsibilities

4.1. The Board of Directors is responsible for the high-level oversight of the determination and operation of notification, investigation and sanction mechanisms in the event of non-compliance with the Policy, rules and regulations.

4.2. Human Resources is responsible for supporting the Board of Directors in establishing a working environment that is committed to ethical values, reliable, compliant with relevant laws and legislation and controlled. Human Resources is responsible for the preparation, development, updating and execution of this policy. Human Resources evaluates the Anti-Bribery and Anti-Corruption Policy, the Code of Business Ethics and Social Compliance Policy and the Disciplinary Regulation and Procedure in terms of currency and development needs, and updates and/or renews them when necessary. In the activities for which they are responsible, Human Resources is responsible for;

4.2.1. Taking the necessary measures to ensure the compliance of employees in their area of duty with the principles of the Policy,
4.2.2. Evaluating possible risks and their effects in terms of corporate reputation and finances,
4.2.3. Taking the necessary measures regarding the establishment and implementation of risk-reducing measures for the management of identified risks,
4.2.4. Reporting matters to the Disciplinary Board for the examination of issues contrary to the Policy,
4.2.5. Taking the necessary measures for the compliance of companies from which external services are received and of business partners with the Policy.

4.2.6. Petaş Ambalaj employees;

4.2.6.1. Ensuring compliance with the policies determined by the Board of Directors,
4.2.6.2. Working in compliance with internal and external legislation,
4.2.6.3. Are responsible for making a notification to the Quality Management Systems unit, which is independent of all units and reports directly to Senior Management, in the event of encountering a behaviour, activity or practice contrary to the Policy.
4.2.6.4. Compliance of companies from which external services are received and of business partners, including support services, with the principles of the Policy and other related regulations is mandatory, and work with persons and organizations that do not comply with these is terminated.

4.2.7. Publication of the prepared document on the corporate portal is the responsibility of the Petaş Ambalaj Information Technologies Officer.

4.2.8. Internal distribution of the prepared document is the responsibility of Quality Management Systems.

5. Implementation

5.1. Bribery and Corruption

As an indication of the sensitivity it shows on business ethics, Petaş Ambalaj has established an anti-bribery and anti-corruption policy. Bribery and corruption may be carried out in many different ways, including:

5.1.1. Cash payments, political or other donations,
5.1.2. Commission,
5.1.3. Facilitation payments,
5.1.4. Social benefits,
5.1.5. Gifts, representation and hospitality other than the form defined in the Code of Business Ethics and Social Compliance Policy,
5.1.6. Hiring a relative,
5.1.7. Other benefits,
5.1.8. Promotion etc.

Within the scope of the principles set out in this Policy, we undertake to carry out our activities in a fair, transparent, honest, legal manner and in accordance with ethical rules. While being extremely sensitive on the fight against bribery and corruption, we stand against bribery and corruption and do not tolerate activities involving bribery and corruption. In this regard, offering, implying, receiving or giving a bribe is unacceptable. We adopt as a principle that the business relationship with third parties wishing to work with Petaş Ambalaj through bribery is not continued. Our employees are not penalized for delay or loss of gain arising from refusing to give or receive a bribe. We ensure compliance with local laws, regulations and principles relating to the fight against bribery and corruption and those of the countries in which we operate. In the sectors in which we operate, we comply with the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and other anti-bribery and anti-corruption legal regulations.

5.2. Relations with the Public

It is unacceptable to give any valuable gift and/or thing to a Public Official, or to undertake or imply any payment, indirectly or directly, for the purpose of influencing an official act or decision. In addition, our employees may not give bribes to public officials, indirectly or directly, for the purpose of obtaining benefit in public affairs. For this reason, our employees are obliged to act in accordance with our Group’s Anti-Bribery and Anti-Corruption Policy.

5.3. Agreements

As Petaş Ambalaj, we take care to act in compliance with this policy in the agreements to which we are a party, in the event of initiating or continuing a business relationship, and in public or non-public tenders. In addition, as Petaş Ambalaj, we aim to act in accordance with this policy in company merger and acquisition transactions and joint venture processes, and we expect the target companies or the companies with which we work in these processes also to act in compliance with this policy.

5.4. Facilitation Payments

As Petaş Ambalaj, we do not permit facilitation payments to secure or accelerate a routine transaction or process with public institutions (obtaining permits, licences, tender procedures etc.).

5.5. Donations and Gifts

The principles relating to donations and gifts at Petaş Ambalaj and the recording thereof have been regulated in detail in the Petaş Ambalaj Code of Business Ethics and Social Compliance Policy. Our employees may not accept or offer any gift that would impair their independence in their relations with public employees, customers, suppliers and other business partners. We take care not to give rise to situations that may lead to or be perceived as a conflict of interest, and not to offer or accept gifts in such situations.

5.6. Keeping of Records

5.6.1. Keeping and preserving all kinds of accounts, invoices and documents relating to relations with third parties (customers, suppliers, other service providers etc.) in a complete, transparent, precise, fair and reliable manner,
5.6.2. Establishing internal control systems that will prevent off-the-record transactions,
5.6.3. We take care that no changes are made to accounting or similar commercial records relating to any transaction and that the facts are not distorted.

5.7. Representation and Hospitality

Representation and hospitality event activities include;

5.7.1. Social events,
5.7.2. Accommodation,
5.7.3. Meal invitations.

Petaş Ambalaj may carry out representation and hospitality activities in order to develop its commercial relations and to establish a commercial communication network. We endeavour to keep these event activities at a reasonable level. We take care that representation and hospitality does not take place prior to a fundamental and important decision-making process.

5.8. Training and Communication

Our Anti-Bribery and Anti-Corruption Policy has been announced to Petaş Ambalaj employees and is easily accessible on the institution’s website. Trainings are organized in order to raise awareness among our employees on anti-bribery and anti-corruption.

For your suggestions, wishes and complaints, you may reach us at info@petasambalaj.com.tr.