1.PURPOSE

The purpose of this procedure is to establish the principles for preventing all forms of violence, harassment, mobbing, discrimination, and unethical behavior that may occur in the workplace; to ensure that employees operate in a safe, healthy, and respectful working environment; and to define the principles for the fair, impartial, confidential, and effective handling of reports and complaints.

Our company considers the protection of employees’ physical and psychological well-being, the promotion of a working environment consistent with human dignity, and equal treatment for all employees as fundamental corporate responsibilities.

2.SCOPE

This procedure applies to:

• All employees,
• Managers,
• Interns,
• Temporary personnel,
• Subcontractor employees,
• Suppliers,
• Service providers,
• Customers,
• Visitors.

Behaviors occurring within the workplace, during field operations, in digital communication environments, during business travel, and in all work-related environments are evaluated within the scope of this procedure.

3.DEFINITIONS

Physical Violence

Any form of assault, battery, pushing, threats, or similar behavior intended to harm a person’s physical integrity.

Psychological Violence / Mobbing

Persistent behaviors aimed at intimidating, excluding, devaluing, pressuring, or psychologically disturbing an employee.

Sexual Harassment

Verbal, physical, written, or behavioral acts of a sexual nature carried out without a person’s consent.

Verbal Violence

Communication behaviors involving insults, threats, humiliation, shouting, or degrading remarks.

Digital Harassment

Inappropriate, disturbing, or threatening behavior conducted through telephone, email, messaging applications, social media, or other electronic communication tools.

Discrimination

Unfair and unequal treatment of individuals based on language, religion, race, gender, age, marital status, disability, ethnic origin, or similar reasons.

4.FUNDAMENTAL PRINCIPLES

Our company:

• Adopts a zero-tolerance approach against violence, harassment, mobbing, and discrimination,
• Supports a safe, respectful, and inclusive working environment,
• Evaluates all applications in accordance with the principle of confidentiality,
• Acts in line with the principles of impartiality and fair assessment,
• Does not permit retaliation against individuals who file complaints or participate in the process,
• Protects good-faith applications.

5.COMPLAINT AND REPORTING CHANNELS

Employees may submit reports or complaints through the following channels:

• Written or verbal application to the Human Resources department,
• Corporate email notification,
• Secure reporting box,
• Anonymous reporting form,
• Application through a manager.

Applications may be submitted anonymously. All reports are evaluated based on the principle of good faith.

6.COMPLAINT PROCESS

• All applications are recorded.
• Evaluation of applications shall begin within 72 hours at the latest.
• The review process is conducted in accordance with the principles of impartiality, confidentiality, and fairness.
• Where necessary, statements and defenses of the relevant parties may be obtained.
• Investigations are conducted by authorized management or an evaluation committee.
• The process is intended to be concluded as quickly as possible.
• Protective and preventive measures may be implemented when deemed necessary.

7.CONFIDENTIALITY

All application, evaluation, and investigation processes are carried out in accordance with the principle of confidentiality.

Information and documents related to complaints are protected so that they are accessible only to authorized persons. Personal data obtained during the process are processed and stored in compliance with the applicable Personal Data Protection Law (KVKK).

8.PROHIBITION OF RETALIATION

The following actions against individuals who submit complaints, provide testimony, or participate in the investigation process are strictly prohibited:

• Pressure,
• Threats,
• Exclusion,
• Discrimination,
• Punishment through reassignment,
• Behaviors that may result in loss of rights.

Retaliatory behaviors are also subject to disciplinary procedures.

9.FALSE AND MALICIOUS REPORTS

If individuals knowingly submit false, misleading, or malicious reports, company disciplinary procedures may be applied against them.

However, lack of sufficient evidence alone shall not be considered an indication of bad faith.

10.INVESTIGATION AND DISCIPLINARY PROCESS

If conduct contrary to this procedure is identified as a result of the evaluation:

• Disciplinary procedures may be implemented,
• Warnings, reassignment, or employment-related actions may be carried out,
• Notifications may be made to legal authorities where necessary.

The company reserves the right to take necessary temporary or permanent measures to protect employee safety.

11.MANAGEMENT RESPONSIBILITIES

Company management undertakes to:

• Support the establishment of a safe and respectful working environment,
• Take necessary measures to prevent violence, harassment, and mobbing,
• Ensure that all applications are evaluated impartially and effectively,
• Support employees’ secure access to complaint mechanisms,
• Encourage awareness and training activities.

12.TRAINING AND AWARENESS

Our company supports:

• Organizing regular training programs aimed at preventing violence, harassment, mobbing, and discrimination,
• Conducting awareness-raising and informational activities for employees,
• Developing an ethical working culture.

13.RETENTION OF RECORDS

Complaint applications, evaluation records, and related documents are securely maintained.

Records are protected to ensure access only by authorized persons and are retained in accordance with applicable legislation.

14.EFFECTIVENESS

This procedure shall enter into force on the date of its publication.

Company management reserves the right to amend this procedure whenever deemed necessary.