1. PURPOSE
As RHG Enertürk Enerji Üretim ve Ticaret A.Ş. ("RHG Enertürk", "the Company"), we adopt the principle of compliance with the relevant legal principles, legal regulations on bribery and corruption, ethical and professional principles in all countries we operate and represent. This policy aims to support the conduct of our activities as RHG Enertürk in an accurate, fair and honest manner in accordance with the relevant laws, regulations, procedures, RHG Enertürk Code of Ethics and other regulations. We have established our Anti-Bribery and Corruption Policy to protect the rights of all Company stakeholders.
This document aims to clearly define RHG Enertürk and its subsidiaries' anti-bribery and corruption approach and policy in accordance with global ethical values and relevant legislation.
2. SCOPE
This policy covers the following;
· The managers and employees of RHG Enertürk Enerji Üretim ve Ticaret A.Ş. and all its subsidiaries,
· Companies and their employees from which we buy goods and services and,
· Persons and organizations working on behalf of RHG Enertürk, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom RHG Enertürk has a commercial relationship ("Business Partners")
3. DEFINITIONS
Company: RHG Enertürk Enerji Üretim ve Ticaret A.Ş. ("RHG Enertürk").
Employee: RHG Enertürk managers and employees.
Ethics Committee: The senior authorized board of RHG Enertürk, which is responsible for the conduct of the Company's activities within the framework of ethical rules within the scope determined in the Ethics Policy of RHG Enertürk, evaluates and decides on ethical notification issues and has the title of the final decision-making authority on ethical issues for all employees.
Ethics Committee Chairman: The representative authorized by the Ethics Committee.
Disciplinary Committee: The committee that evaluates and decides on the ethical notification issues regarding the employees with the title of Manager/Director and below in the Company.
Bribery: The act of a person deviating from the requirements of their duty by making an agreement with a third party and benefiting in a certain way, such as performing or not performing a task, expediting or delaying it.
Corruption: The requesting, offering, giving or accepting of bribes or any other form of illegal benefits that leads to deviations from the lawful performance of the duties or required behaviors carried out by the person who directly or indirectly obtains such bribes or illegal benefits because of the position held.
Gift: Goods and services that do not require a monetary payment and are usually given as a way of saying thank you or as a business courtesy by business partners or suppliers.
4. DUTIES AND RESPONSIBILITIES
The Board of Directors of RHG Enertürk is responsible for establishing, implementing and updating the Anti-Bribery and Corruption Policy. We impose disciplinary penalties in case employees violate these principles. The Ethics Committee and the Disciplinary Committee appointed by the Company's Board of Directors are authorized to review such cases. The Board of Directors ensures the development of the Ethics Committee and Disciplinary Committee and monitors its activities.
The Board of Directors, through the Ethics Committee, ensures that the necessary communication channels are established to report any behavior contrary to this policy and takes measures to ensure the confidentiality and security of the persons making such reports.
COMPANY EMPLOYEES
Company employees are responsible for carrying out all their activities in accordance with the relevant laws and regulations, RHG Enertürk Ethics Booklet and Disciplinary Regulation.
RHG Enertürk employees are obliged to act in accordance with the principles in the policy and may not be forced to act contrary to the Policy. Employees are obliged to report all behaviors and practices contrary to the policy to their managers and/or the Ethics Committee and Disciplinary Committee.
Managers are responsible for the implementation of the principles in the policy in a proper manner by the employees, subcontractors and their employees and business partners for whom they are responsible.
5. ANTI-BRIBERY AND CORRUPTION APPROACH
As RHG Enertürk, we always aim to fully comply with the relevant laws, regulations, commitments and global ethical principles, especially the UN Global Compact, and we do not tolerate any act of bribery and corruption, regardless of its purpose.
No business relationship shall be established with third parties who engage in or offer practices that may be considered as bribery and corruption, and the existing business relationship shall be terminated immediately.
Within the framework of the Anti-Bribery and Corruption Policy, we aim to ensure that all violations identified within the scope of our company's activities can be reported by the Ethics Committee to the senior management of our Company by examining the complaints reported to the Ethics Committee and Ethics Line.
ETHICS COMMITTEE AND DISCIPLINARY COMMITTEE
RHG Enertürk Ethics Committee and Disciplinary Committee conducts studies and gives opinions to solve the problems encountered during the implementation of the Policy. RHG Enertürk Ethics Committee and Disciplinary Committee aims to take reasonable steps to ensure that the parties covered by this Policy act in accordance with this Policy, such as auditing employees to identify inappropriate behavior.
RHG Enertürk Ethics Committee consists of a chairman, three members, an independent member (if needed, an expert consulted on the relevant subject) and a secretariat, and following the approval of the Board of Directors, it is announced to all employees by the Human Resources Department and starts its activities. Duties and Responsibilities of the Ethics Committee:
· To investigate complaints and denunciations of violations of the Code of Ethics within the Company,
· To resolve the investigated violations of the Code of Ethics or having them resolved,
· To make opinions and suggestions for the implementation of the Code of Ethics,
· To respond to applications made for consultation within the scope of RHG Enertürk Code of Ethics,
· To ensure that the Code of Ethics is in compliance with the relevant legal regulations,
· To inform employees about the Code of Ethics and to be in constant communication with employees to ensure the comprehensibility of policies and rules,
· To ensure that all new hires and employees read the Code of Ethics and are informed about it.
All our employees can verbally report their questions about the code of ethics and suspected violations, or they can use the Ethics Committee's communication channels listed below.
E-mail: etik@enerturk.com
Address: Huzur Mah. Azerbaycan Cad. Skyland Sitesi B Blok Kat:16 No:4B/240 34485 Sarıyer, İstanbul,
The Ethics Committee and the Disciplinary Committee meticulously handle the complaints and denunciations received, ensure that there is evidence/documents, etc. required for the decision and initiate the necessary investigation through the Disciplinary Committee. If a rule violation is detected, they take the necessary measures and decisions with a common opinion.
Other documents supporting the implementation of this policy are RHG Energy Code of Ethics Booklet and Disciplinary Regulation.
6. MAJOR RISK AREAS FOR ACTS OF BRIBERY AND CORRUPTION
Examples of risk areas where bribery and corruption may occur are described below.
A: Gifts and Gratuities
· Gifts may not be accepted from customers, suppliers and other third party stakeholders in exchange for doing or undertaking to do any business.
· Gifts may not be requested from customers, suppliers and other third party stakeholders.
· Gifts with a cash value, such as cash or cash equivalent gift cards, may not be accepted.
Gifts that exceed the limits specified in our Company's Code of Ethics Booklet and Gift Procedure may not be accepted. Acceptable gifts include advertising and promotional products (agendas, pens, calendars, etc.) that are distributed to everyone and have symbolic value for promotional purposes within legal limits; and gifts given as souvenirs at public conferences, forums, panels, dinners or similar events.
In principle, gifts should not be accepted from business partners, customers, suppliers and other third party stakeholders. However, it is possible to accept gifts if the gifts to be given or received are in accordance with commercial practices, remain within the framework of goodwill and do not affect the objectivity of company decisions. In exceptional cases, gifts of low monetary value that employees cannot refuse and that may damage the business relationship may be accepted. These gifts are specified in the Code of Ethics Booklet.
B: Facilitation Payments
Individuals and entities covered by this policy are not allowed to offer facilitation payments to secure or expedite a routine transaction or process with government agencies.
C: Donations
As RHG Enertürk, we likewise do not agree to pay or make financial/material contributions to political parties, politicians, political organizations, representatives of such groups and candidates or any organization for direct or indirect facilitating transactions related to the company.
Company employees may make donations and grants on their own behalf, using their own resources, independent of their jobs.
D: External Service Providers and Business Partners
The Company conducts due diligence before evaluating the companies and business partners from which it intends to outsource services, including support services. The Company does not work with individuals and organizations that have negative intelligence on bribery or corruption.
Companies and business partners that receive external services are obliged to comply with this policy and other relevant regulations. The Company informs these companies and business partners about this policy. No business relationship may be established with persons and organizations that do not comply with these rules and other regulations, and existing relationships are terminated immediately.
E: Education and Communication
This Policy has been announced to the Company employees and is constantly and easily accessible by the Company employees through https://enerturk.com/.
Trainings are organized to raise awareness of employees on anti-bribery and corruption. These trainings are provided to all employees and the Board of Directors of the Company in accordance with their duties and are updated and repeated as needed and according to amendments in the relevant legislation.
The Ethics Committee is responsible for the preparation and delivery of relevant trainings and may request assistance from the human resources department.
These trainings are included in the orientation programs of new employees.
7. POLICY COMPLIANCE AND MANAGEMENT OF VIOLATIONS
RHG Enertürk employees are obliged to comply with the relevant legal regulations on anti-bribery and corruption, company commitments, especially the UN Global Compact, global ethical rules and this policy. In the event that Company employees act in violation of the rules set forth in this policy, disciplinary procedures shall be carried out. In addition, those who do not comply with the relevant legal regulations and applicable anti-corruption laws may be subject to criminal liability.
Our employees shall not be subjected to practices that will negatively affect the employee's career, such as ill-treatment, prevention of promotion, change of duty, or deprivation of rights because they refuse to participate in a practice contrary to this policy or express their concerns about practices or initiatives that they believe violate our policies and ethical principles.
8. POLICY RELATED QUESTIONS
All questions about the policy should be reported to the HR Manager or the Ethics Committee.