Code of Conduct Ethics and Social Compliance Policy

Purpose

The fundamental moral and ethical values at Petaş Ambalaj are as follows;

Honesty
Tolerance
Humility-Modesty
Respect for Opinions and Beliefs
Leadership
Diligence
Justice

The purpose of the Code of Business Ethics and Social Responsibility Policy established within the framework of these moral values is to ensure;

The sustainability of the existing environment of trust,
An increase in quality (Process, Product and People),
An increase in Customer Satisfaction,
An increase in stakeholder satisfaction,
An increase in employee loyalty,
An increase in integrity and effectiveness in decisions and activities as a result of an increased environment of trust in internal/external workplace relations,
A positive increase in sustainable profitability.

Scope

All employees.

Definitions

Ethics: The set of rules and norms that people are expected to follow in their relations with each other, their suppliers, customers, consumers, competing companies and the state, and that ensure social order.

Responsible Parties

The Human Resources Directorate together with all Department Managers are responsible for the implementation and follow-up of this procedure.

Implementation

Our Business Ethics

Honesty

Accuracy and honesty are our primary values in all our business processes and relationships. We act with accuracy and honesty in our relations with employees and all our stakeholders.

Tolerance

We value our employees, our customers and people. We show understanding towards their lifestyles and thoughts.

Humility-Modesty

We adopt humility as a form of behaviour in our relations with our employees and customers both inside and outside the company.

Respect for Opinions and Beliefs

We respect all beliefs and opinions of our employees, customers and suppliers by remaining at an equal distance.

Leadership

We lead positive developments and innovations in matters related to our sector.

Diligence

As a requirement of the respect we have for our work and ourselves, we expend maximum effort and endeavour in matters related to our work.

Justice

We protect the rights of our company, our employees, our customers and our suppliers by showing the necessary sensitivity and respect.

Our Business Ethics Responsibilities

In addition to our legal responsibilities, we take care to fulfil the responsibilities listed below towards our customers, employees, shareholders, suppliers and business partners, competitors, society, humanity and the name of Petaş Ambalaj.

Our Legal Responsibilities

We conduct all our existing activities and transactions in Türkiye and abroad within the framework of the laws of the Republic of Türkiye and international law, and we submit accurate, complete and understandable information to legal regulatory institutions and organizations in a timely manner. While conducting all our activities and transactions, we remain at an equal distance from all kinds of public institutions and organizations, administrative formations, non-governmental organizations and political parties without any expectation of benefit, and we fulfil our obligations with this sense of responsibility.

Our Responsibilities Towards Our Customers

We work with a proactive approach that is focused on customer satisfaction and that responds to our customers’ needs and requests in the shortest time and in the most accurate manner. We provide our services on time and under the conditions we have promised; we approach our customers within the framework of respect, dignity, justice, equality and courtesy.

Our Responsibilities Towards Our Employees

We ensure that our employees’ employment rights are used fully and accurately. We approach our employees honestly and fairly, and we commit to a non-discriminatory, safe and healthy working environment. We make the necessary effort for the individual development of our employees, support them in volunteering for appropriate social and community activities in which they will take part with a sense of social responsibility, and observe the balance between work life and private life.

Our Responsibilities Towards Our Partners

Giving priority to the continuity of Petaş Ambalaj and in line with the goal of creating value for our partners; we refrain from taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability, and we manage our company’s resources and assets and our working time with an awareness of efficiency and savings.

Our Responsibilities Towards Our Suppliers/Business Partners

We act fairly and respectfully as expected of a good customer, and we show the necessary care to fulfil our obligations on time. We carefully protect the confidential information of the persons and organizations we do business with and of our business partners.

Our Responsibilities Towards Our Competitors

We compete effectively only in legal and ethical areas and refrain from unfair competition. We support efforts aimed at ensuring the targeted competitive structure in society.

Our Responsibilities Towards Society and Humanity

With the awareness of being a good citizen, we act sensitively as a pioneer on social issues; we try to take part in non-governmental organizations, services in the public interest and appropriate activities on these matters. We act with sensitivity towards the traditions and cultures of Türkiye and of the countries in which we carry out international projects. We do not give or accept bribery or gifts, products and services of a value exceeding their purpose.

Our Responsibilities Towards the “Petaş Ambalaj” Name

Our business partners, customers and other stakeholders trust us thanks to our professional competence and honesty. We strive to maintain this reputation at the highest level. We provide our services within the framework of Company policies, professional standards, the commitments we have given and ethical rules, and we show the necessary dedication to fulfil our obligations. We do not work with those who harm public morals or who harm the environment and public health.

Policies Supporting Business Ethics

Confidentiality

Confidential and private information covers information belonging to Petaş Ambalaj that may create a disadvantage in terms of competition, trade secrets, financial and other information not yet disclosed to the public, information relating to personnel employment rights, and information within the framework of “confidentiality agreements” concluded with third parties.

As Petaş Ambalaj employees; we take care to protect the confidentiality and private information of our customers, our employees and other relevant persons and organizations with which we work. We protect confidential information relating to company activities, use this information only for the purposes of Petaş Ambalaj, and share this information only with the relevant persons within the determined authorities.

Conflict of Interest

As Petaş Ambalaj employees, we aim to stay away from conflicts of interest. By making use of our current position; we do not obtain personal benefit from persons and organizations with which we have a business relationship, personally or through our family or relatives. We do not engage in a business activity based on an additional financial interest outside Petaş Ambalaj. We refrain from using the name and power of Petaş Ambalaj for the purpose of obtaining personal benefit.

Abuse of Position

It is unacceptable for employees to harm the Company by using their authority for their own and/or their relatives’ benefit and outside the care expected of them.

Employees may not obtain personal gain, directly or indirectly, from the Company’s purchasing and sales activities and from all transactions and contracts to which the Company is a party.

Employees may not engage in acts and behaviours contrary to morals, the law and Company discipline.

Use of Resources

In the use of resources on behalf of the Company, the Company’s interests are taken into account. Without Company interest, Company assets, facilities and personnel may not be used outside the Company under any name and for the benefit of anyone. The principle of “savings in every matter” is applied by all personnel.

The correct use of resources for the Company’s benefit also requires the correct use of time. During working hours, Company employees use time well and do not allocate time to their private affairs during working hours. Managers may not assign employees for their personal work.

It is essential that private visitors are not received during working hours. For obligatory visitors, employees are required to complete meetings within a reasonable time, in connection with the subject of the visit and in a manner that does not disrupt the workflow.

Relations with Other Persons and/or Organizations with which the Company Has Commercial Relationships

A private business relationship may not be entered into with Company customers, subcontractors or suppliers and other persons and/or organizations with which the Company has a commercial relationship; money and/or goods/services may not be borrowed for personal purposes, and money and/or goods/services may not be lent to other persons and/or organizations with which the Company has a commercial relationship.

The following points are taken into account in relations with customers; even if it is in the customer’s favour, a transaction may not be carried out without the customer’s knowledge, and even if it is in the company’s favour, customer weaknesses may not be exploited and profit may not be pursued by giving incomplete or inaccurate information to the customer.

Company personnel may not request gifts from other persons and/or organizations with which the Company has a commercial relationship, nor imply such a request; they may not accept any gift, money, cheque, property, free holiday, special discounts etc. that would place the Company under an obligation. Personal assistance or donations may not be accepted from any person or organization that has a business relationship with the Company.

Confidential Information Protection Policy

Information is one of the most important assets that Petaş Ambalaj will use on the path to realizing its vision. In this regard, the effective use of information, its correct sharing, and ensuring the confidentiality, integrity and accessibility of information in this process are the common responsibility of all employees. The following implementation principles define confidential information for our Company and regulate the principles that employees must comply with regarding confidential information.

Implementation Principles

Confidential Information covers, without limitation, trademarks and other intellectual rights belonging to Petaş Ambalaj, databases written, invented, developed, made or put into practice by personnel including all kinds of innovation, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, information relating to strategic partnerships and partners, financial information, personnel information, customer lists, product designs, know-how, specifications, the identity of potential and actual customers, information relating to suppliers, and all kinds of written, graphic or machine-readable information.

The principles that must be complied with regarding confidential information are as follows;

This information may not be disclosed to third parties unless disclosure is mandatory pursuant to Official Authorities and Legislation.
This information may not be altered, copied or destroyed. The necessary measures are taken for the information to be kept carefully, stored and not disclosed. Changes to the information are recorded together with their history.
Confidential files may not be taken outside the institution. For confidential information that needs to be taken outside the institution, the approval of the person responsible for the information or of senior management must be obtained.
Passwords, user codes and similar identifying information used to access Company information are kept confidential and are not disclosed to anyone other than authorized users.
Company confidential information is not discussed in dining halls, cafeterias, shuttle vehicles and similar public places.
Company personnel know the confidentiality degrees of the information they obtain by reason of their duties and act in accordance with this confidentiality. In the event of any hesitation as to the degree of confidentiality, action is taken according to a higher confidentiality class and the opinion of the relevant manager is obtained when necessary.
If information is to be shared with third persons and/or organizations for the Company’s benefit, a confidentiality agreement is first signed for information sharing, or a written confidentiality undertaking is obtained from the other party, in order to guarantee that these persons and organizations understand their responsibilities regarding the security and protection of the shared information.
Unfounded statements and/or gossip about persons or institutions may not be made.
Personnel wages, fringe benefits and similar personal information that reflect Company policy and are personal are confidential and may not be disclosed to anyone other than authorized persons. Personnel information is sent personally. It is strictly forbidden for personnel to disclose this information to others or to pressure other employees to disclose the information.

Policy to Create and Maintain a Fair Working Environment

Petaş Ambalaj considers the creation and maintenance of a fair working environment for employees as one of its most important priorities. The aim is to create a fair, employee-respectful, healthy and safe working environment that is compatible with all relevant laws and regulations, and to increase the success, development and commitment of employees. The following implementation principles determine the basic principles regarding the creation and maintenance of a fair working environment at Petaş Ambalaj.

Implementation Principles

Company practices are compatible with all relevant laws and regulations in force regarding employment and working life. Company employees also fulfil all legal requirements within the scope of their own activities and act in accordance with legal regulations.
Petaş Ambalaj Human Resources Policy and Practices ensure that recruitment, promotion-transfer-rotation, remuneration, rewarding, social benefits and all other practices are fair.
Discrimination among employees within the institution on grounds of language, race, colour, gender, political opinion, belief, religion, denomination, age, physical disability, trade union and NGO membership and similar reasons is unacceptable.
At Petaş Ambalaj, a positive and harmonious working environment that supports cooperation is created, conflict environments are prevented, and people with different beliefs, thoughts and opinions are enabled to work in harmony.
Respect is shown for employees’ private lives and personal spaces.
Communications between persons may not be violated by persons who are not parties thereto.
Even if recorded in accordance with the law, the unlawful giving/dissemination/obtaining of personal data by others is prohibited.
Personnel employment information arising from the nature of the employment relationship in workplaces and that may be necessary thereafter is not used for purposes other than its intended purpose and is not shared with third parties without the consent of the persons.
Respect is shown for the private and family lives of all employees.
In addition to all kinds of inviolability of employees, their physical, sexual and emotional inviolability is also observed.

The violation of employees’ inviolability in any way through physical, sexual and/or emotional harassment at the workplace or at any place they are present by reason of work is contrary to the law and ethical rules, and no tolerance is shown by the Company for this offence. The purpose of this practice is to enable employees to work in a work environment in which their physical, sexual and emotional inviolability is protected.

The violation of a person’s bodily inviolability through sexual conduct, without gender distinction, and/or the harassment of a person for sexual purposes without physical contact is defined as sexual harassment. Accordingly; the exhibition of any behaviour that may be evaluated within this definition is prohibited. In addition, again without gender distinction, all situations that may cause sexual abuse or economic abuse among employees or among employees in a superior-subordinate relationship are examined with sensitivity and zero tolerance is shown.

In addition, the same lack of tolerance is shown towards those who exhibit negative attitudes and behaviours towards persons who complain or report any harassment or who assist during an investigation.

No employee may request privileged treatment due to a different gender, religion, language or race, may not show privilege to anyone, and may not be subjected to a special practice. Obtaining or granting concessions by making use of differences such as gender, religion, language or race is unacceptable.
It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.

5.4.1. Forced Labour (Voluntary Work)

Our workplace prohibits all forms of forced labour, including prison labour, apprenticeship contracts, bonded labour, military labour or slave labour and all kinds of human trafficking. Work may not be performed outside the working hours specified in the law (regular/overtime). Overtime work may not be performed without the employee’s consent. If the employee leaves the job, the company may not prevent or delay this except for any security reason. All information of our employee is protected and kept confidential to the extent specified by the laws.

5.4.2. Child Labour

This is explained in the Child and Young Worker Rehabilitation Procedure.

5.4.3. Discrimination

Our workplace values all its employees and the contributions they provide. It has a deep-rooted commitment to standing against discrimination and ensuring equal opportunity. As management, we are determined to maintain our organization as an institution free from discrimination or physical or verbal harassment on the basis of race, gender, colour, nationality, social origin, language, religion, age, disability, political opinion, migrant worker status or any status protected by applicable laws. Personnel selection for our workplace is made on the basis of minimum qualifications such as open position, training, areas of interest, talent and work experience.

5.4.4. Working Hours and Wages

Wage Management Procedure
Recruitment Procedure

5.4.5. Health and Safety

Our company ensures the creation and preservation of a safe and healthy workplace environment. The company aims to create a work environment in which our employees can work safely, healthily and productively by minimizing the risk of exposure to accidents, injuries and all kinds of factors that threaten health, and to ensure its continuity. A workplace environment free from all kinds of violence, pressure, harassment, threats, discrimination and disturbing conditions is provided at our company.

5.4.6. Commitment to Society and Stakeholders

Our company undertakes to establish a bond with its stakeholders on the basis of good faith by listening to their views, obtaining information from their views and taking their views into account. In this context, it determines employee representatives in accordance with legal legislation, creates an environment in which employees can discuss their problems with the representatives, and enables them to report in writing to suggestion boxes. Where appropriate, it undertakes to establish a dialogue with its stakeholders on workplace rights issues related to the workplace and within its sphere of influence.

5.4.7. Foreign National Employees

For foreign national employees working within our company; all employment procedures from recruitment to termination are conducted in accordance with the legal legislation in force and no discrimination is made. The worker may not under any circumstances be employed by being indebted. The legal rights of foreign workers regarding employment are protected by the Company.

5.4.8. Human Trafficking

Our company does not employ illegal workers and does not establish a business partnership with companies and suppliers that do so.

5.4.9. Environment and Occupational Health and Safety

As Petaş Ambalaj, one of our objectives is also to ensure Environment and Occupational Health and Safety to the maximum extent. Establishing life, property and environmental safety by minimizing the risks to which our environment and all parties affected by our activities may be exposed; meeting and improving legal conditions, raising the level of awareness on this subject, and ensuring that our understanding of social responsibility is understood in society, including our customers, are among our priorities.

5.4.10. Right to Organize, Unionize and Collective Work (Freedom of Association)

We undertake to respect the right of all employees to organize, unionize and engage in collective work within the framework of legal regulations; and not to put pressure on or discriminate against employees who exercise the right to organize, unionize and engage in collective work.

Our employees;

Have the right to elect worker representatives of their own free will by secret ballot.
Are not prevented from becoming members of all NGOs and trade unions that are not illegal / do not engage in illegal activities. No sanction is applied to member personnel under any circumstances or conditions.
Employee representatives may freely express their wishes and requests on all platforms in which they participate. No sanction may be applied for this reason.
Their right to participate in possible strike / lockout events is not prevented.
If employees and worker representatives raise / report any matter, no sanction may be applied for or against the employees. (Malicious work and reports are investigated by the disciplinary board.)

Our General Responsibilities

Employee Responsibilities

The relevant policies and procedures have determined in detail the ethical rules regarding how we should behave and how we should do our work. Compliance with these rules is the primary responsibility of all employees. In this regard, all Petaş Ambalaj employees have the responsibility to;

Act in accordance with laws and regulations under all circumstances,
Read the Petaş Ambalaj Code of Business Ethics, know, understand, internalize and act in accordance with the rules, principles and values contained therein,
Learn the general and job-specific policies and procedures applicable to the Company,
Consult their manager and human resources regarding potential violations concerning themselves or others,
Report possible violations by themselves or others promptly; convey their notifications on these matters named or anonymously to their manager and/or human resources in writing or verbally,
Cooperate in ethics investigations and keep information relating to the investigation confidential.

Responsibilities of Managers

Petaş Ambalaj managers also have additional responsibilities beyond the responsibilities defined for employees within the framework of the Ethical Rules. Accordingly, Managers are responsible for;

Ensuring the creation and maintenance of a company culture and working environment that supports ethical rules,
Setting an example with their behaviour in the implementation of ethical rules and training their employees on ethical rules,
Supporting their employees in conveying their questions, complaints and notifications regarding ethical rules,
Guiding on what needs to be done when consulted, taking into account all notifications conveyed and forwarding them to Senior Management as soon as possible when deemed necessary,
Ensuring that the business processes under their responsibility are structured in a way that minimizes risks related to ethical issues, and applying the necessary methods and approaches to ensure compliance with ethical rules.

Employees are free to report unethical behaviour to the BSCI management representative other than their managers. The BSCI management representative applies an open-door policy in supporting ethical compliance.

Other Responsibilities

Company senior management is responsible for;

The effective implementation of the Code of Business Ethics and the creation of a culture in which this is supported,
Guaranteeing the confidentiality of complaints and notifications made within the framework of the Ethical Rules and protecting individuals after their notifications,
Ensuring the job security of employees who make a notification,
Guaranteeing that complaints and notifications are investigated in a timely, fair, consistent and sensitive manner, and taking the necessary actions as a result of violations with determination.

Rules

The references are as follows:

Laws of the Republic of Türkiye
Customs and traditions accepted in society
Corporate culture

All matters related to social compliance issues have also been guaranteed and undertaken by procedures.

There is an Ethics Phone Line at our company. The related process is as follows:

When our personnel, coincidentally or on their own initiative, detect any irregularity, contact is made with our General Manager via the ethics phone line at our company. The ethics phone line has been announced to all employees by e-mail and via notice boards. The identity information of the person making the report is known only by our General Manager and, if deemed necessary, by the employee assigned by our General Manager to conduct the investigation, and the identity information is not disclosed to anyone other than these persons. Our General Manager submits the reports relating to the investigations conducted to management. The improvement plans that need to be made as a result of these reports and the disciplinary instructions that need to be applied are shared only in the meeting held with unit supervisors, recorded with the Meeting Minutes Form, and the processes are followed. Investigation files and improvement plans are filed in paper form and stored in a place to which only our General Manager has access.

Ethics Phone Line: +90 342 502 3636

Retention of Records

All records are retained in accordance with the Control of Records Procedure.