OUR POLICIES

BUSINESS ETHICS RULES

I. OUR BUSINESS ETHICS RULES

A. Sincerity

In all our business processes and relations, faithfulness and sincerity is our priority. In our relationship with all our employees and business partners we act with faithfulness and sincerity.

B. Confidentiality

Confidential and private informations contains;  any information that gives disadvantage to Ermoda Textile in terms of competition, trade secrets, financial and other infos that are not yet shared with the public, employee’s personal informations and the confidentiality agreements signed with the third parties.

We as employees of Ermoda Community highly care for confidentiality of our clients, employers and third party partners’ private informations. We save confidential infos regarding to Ermoda Textile activities, we only use these informations in accordance with Ermoda Textile’s purposes; we share these informations only with the related persons within the limits of our given authority.

C. Conflict of Interest

We as Ermoda Textile employees aim to stay away from conflict of interest. Taking the benefit of our current duty, we do not derive personal benefits from the persons or companies that we are in business relationship with.

In case of potential conflict of interest, we apply the method which we believe it will safely protect both sides’ benefits in terms of legal and ethics. If we have any hesitation we consult with our managers, Human Recources Department or Ethics Council.

D. Our Liabilities

Besides our legal liabilities we take care of the following responsibilities towards our clients, employers, shareholers, suppliers, business partners, competitors, public, humanity and Ermoda name.

1. Legal Liabilities

We carry out all our national and foreign activities in accordance with Turkish and international regulations. We submit correct, complete and clear informations to legal organizations on time.

While carrying out all our activities and processes, we fulfill our liabilities without any expectation from any kind of public organization, non-governmental organization or political party.

2. Liabilities towards our Clients

Customer satisfaction is our focus therefore we work with proactive perspective to ensure our clients’expectations and requirements correctly and within the shortest time. We submit our services on time and with agreed conditions and our approach towards our clients is within the scope of respect, fairness, equity and kindness.

3. Liabilities towards our Employees

We ensure that our employees use their personal rights in full and in the correct way. Our approach towards our employees is fair and equal and we commit safe, healty and non-discriminatory working conditions for them.

We care for our employees’personal improvement, we support them being volunteer for appropriate social responsibility acts. We also take care about our employees’ private and business life balance.

4. Liabilities towards our Suppliers / Business Partners

As expected from a good customer, we act fair and sincere to our suppliers and we take utmost care to fulfill our liabilities on time. We conscientiously save our business partners’ confidential informations.

5. Liabilities towards our Competitors

We compete effectively in legal and ethic areas and we keep away from unfair competition. We support efforts aimed at achieving the targeted competitive structure in the society.

6. Liabilities towards Society and Humanity

Protection of democracy, human rights and the environment; education and charity, the elimination of crime and corruption is very important to us.  We act sensitively as a pioneer in social issues with the awareness of being a good citizen.  We try to take part in appropriate activities on non-governmental organizations, services for the benefit of the public.  We act sensitively towards the traditions and cultures of Turkey and the countries in which we conduct international projects with. We do not give and accept products and services that are considered to be bribes or gifts.

7. Liabilities towards "Ermoda" name

Our business partners, clients and other stakeholders rely on us for our professional competence and integrity. We try to keep this reputation at the highest level.

We provide our services within the framework of Company policies, professional standards, commitments and ethical rules, and show the necessary dedication to fulfill our obligations.

We take care to serve in areas we believe to be professional and competent, and aim to work with customers, business partners and employees who meet the criteria of accuracy and legitimacy. We do not work with those who damage society morality and harm the environment and public health.

II. POLICIES SUPPORTING BUSINESS ETHICS RULES

A.  Conflict of Interest Policy

It is essential that Ermoda Textile employees stay away from situations that may create a conflict of interest. It is one of the most important responsibilities of all employees to avoid the use of Ermoda Textile resources, name, identity and power for personal benefit and to avoid situations that may adversely affect the name and image of the company. The following principles set out the conflict of interest situations that may be encountered by the company's employees in the course of their duties or due to their business relationships, and the principles to be applied in these situations.

Application Basics

1. Activities that may create a Conflict of Interest

All company employees are required to fully comply with the conditions and principles set out below as activities that may create a conflict of interest. The Company conducts the necessary work to encourage its employees to comply with these principles.

i. To be Engaged in Activities That May Create a Conflict of Interest

Employees can not engage in any business relationship with family members, friends or other third parties with whom they have a requited or unrequited interest. For example, an employee with a purchasing authority should refrain from doing business with a supplier from which one of the family members works. Exceptions are subject to the knowledge and approval of the Chairman of the Board of Directors.

It is essential that Ermoda Textile employees do not engage in activities requiring direct and indirect "merchant" or "tradesmen" and that they do not work for any other person and / or institution within or outside working hours under any name for any wage or similar benefit. However, employees work outside the working hours for another person (family member, friend, other third parties) and / or the organization for remuneration or similar benefits is possible only if;

  • does not create a conflict of interest with the duties they carry out in the company,
  • does not be non-compliance with other business ethics rules and policies supporting these rules,
  • does not adversely affect their performance in the company,
  • getting written approval of the management.

Managers who are in a position to make a recruitment decision cannot hire their spouses, close relatives and their relatives.

ii. Malpractice

It is unacceptable for the employees to use their authority to the benefits of their own and / or their relatives and damage to the company.

Employees may not directly or indirectly gain personal income from the purchase and sale activities of the company.

Employees may not act against the morality, law or company discipline.

 

iii. Use of Resources

In the use of resources on behalf of the Company , Company interests are taken into consideration. Company assets, opportunities and personnel may not be used outside the company under any name and for any name and benefit if it is not for the company's interest. The principle of "saving on everything" is applied by all staff.

Correct use of resources for the benefit of the company also requires the correct use of time. During business hours, company employees use their time effecticely and do not allocate time for private work during business hours. Managers cannot assign employees for their private work.

It is essential that no special visitors are accepted during working hours. For compulsory visitors, employees are required to complete the interviews in a reasonable period of time, in connection with the subject of the visit and without hindering the workflow.

 

iv. Relations with Other Persons and / or Entities in which the Company has Business Relationships

It is not permitted to engage private business relations with customers, subcontractors or suppliers and other persons and / or entities in which the Company has a commercial relationship, borrow money and /or goods / services for personal purposes, and lend money and/or goods / services to other persons and /or entities with which the Company has a commercial relationship.

The following issues are taken into consideration in relations with customers; Even if it is in favor of the customer, no transaction can be performed without the knowledge of the customer and even if it is in favor of the company, the weaknesses of the customer cannot be exploited and no profit can be gained by giving the customer incomplete or incorrect information.

Company personnel may not request or imply gifts from other persons and / or organizations in which the company has commercial relations; can not accept  gifts, money, checks, property, free holidays, special discounts, etc., which will put the company  under obligation.  Employees can not accept any private help and donations from any person or organization that has a business relationship with the company. In such a case Gift Acceptance and Giving Policy is applied.

B. Gift Acceptance and Giving Policy

It is essential that Ermoda Textile and its employees do not accept gifts or benefits that may affect their impartiality, decisions and behaviors, and that they do not attempt to provide gifts and benefits to third parties and organizations that may create such effects. The principles of implementation described below regulate the gift exchanges of the Company employees with third party persons and organizations with whom they have business relations and determine the principles to be applied in this regard.

Application Basics

1. Employees of the Company are prohibited from receiving all kinds of benefits and gifts that affect or have a negative impact on their impartiality, performance and decision-making.

 

2. Company Employees may receive and/or give gifts outlined in Article 3 or they may agree to be subject to special practice only if it is:

•    Consistent with the corporate business objectives

Are in accordance with the applicable legislation

3.  Gifts, benefits, holidays, discounts, etc., other than  money can be accepted  and approval is not required if the total value of the gifts received is less than 250 TL each calendar year and the person / institution giving the gift is different from each other and  it complies with the conditions listed in Article 2.

4. It is forbidden to receive gifts or benefits implied or explicitly linked to a provision.

5. Under no circumstances it can be accepted to receive, give or offer bribes and / or commissions.

6. Company employees are not allowed to accept unpaid or borrowed money from subcontractors, suppliers, consultants, competitors or customers, and also they are not allowed to cover travel expenses, activity expenses and similar payments.

7.The top management of the Company shall approve the gifts and promotional materials to be given to customers, dealers and other third parties with whom the Company has business relations. For the distribution of approved gifts and promotional materials, no separate permission is required.

8. The Company may accept the appropriate products and services as gifts, provided that it complies with the conditions set out in Article 2, and products or services in accordance with the culture and ethical values of the buyer may be given as gifts as per the knowledge and approval of the Company's senior management.

9. In exceptional cases where local cultural values require mutual gifts above the values specified in the company policy, such gifts may only be accepted on behalf of the Company and with the approval of the Company's senior management. In any case, the exchange of gifts must be made in accordance with the local culture.

C. Privacy Policy

Knowledge is one of the most important assets that Ermoda Tekstil will use to realize its vision. Accordingly, it is the joint responsibility of all our companies and employees to ensure the effective use, correct sharing of information and ensuring the confidentiality, integrity and accessibility of information in this process. The management systems established for the management and confidentiality of information in our company and the harmonization of the processes applied are important for the Group to achieve the highest level of benefit.

Application Basics

Confidential Information includes, but is not limited to, the Company's trademark, Intellectual Property Rights, all kinds of innovation, including personnel written, found, developed, made or implemented database, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and partners’ informations, financial informations, personnel informations, customer lists, product designs, specifications, identity of potential and real customers, information about suppliers and so on.

The principles to be followed regarding confidential information are as follows:

1. These informations may not be disclosed to third parties unless it is mandatory to disclose it in accordance with the Official Authorities and Legislation.

2.These informations cannot be changed, copied or destroyed. Necessary precautions should be taken to keep the informations carefully and not to reveal them. Changes to the informations are recorded together with their history.

3. Confidential files cannot be taken out of the company. Confidential information that needs to be taken out of the company must be approved by the responsible person or senior management.

4. Passwords, user codes and similar identifying information used to access company informations are kept confidential and not disclosed to anyone other than authorized users.

5. Company confidential information can not be discussed in dining halls, cafeterias, elevators, trolleys and similar public places.

6. Confidential informations are classified according to the degree of confidentiality and this is clearly stated in the content of the information. Company personnel knows the degree of confidentiality of the information obtained due to their duties and act in accordance with this confidentiality. If there is any doubt about the degree of confidentiality, it is treated according to the upper class of privacy and the opinion of the relevant manager is obtained when necessary.

7. In case any information should be shared with third parties and /or organizations for the benefit of the company, a confidentiality agreement is signed or a written confidentiality agreement is obtained from the other party in order to guarantee the understanding of the responsibilities of these people and organizations regarding the security and protection of shared information.

8. Baseless statements and / or gossips about individuals or institutions cannot be made.

  1. Wages, benefits and similar personal information of the personnel who reflect the Company's policy are confidential and cannot be disclosed to anyone except the authorities. Personnel informations are sent to the related person privately. It is strictly prohibited for staff to disclose this information to others or to put pressure on the other employees to disclose the information.

D. Establishing and Maintaining a Fair Working Environment Policy

Ermoda Tekstil considers the creation and maintenance of a fair working environment as one of its most important priorities. It is aimed to increase the success, development and loyalty of the employees by creating a fair, respectful, healthy and safe work environment in compliance with all relevant laws and regulations. The following principles set out the basic principles for creating and maintaining a fair working environment in the company.

Application Basics

1. Company practices comply with all applicable laws and regulations in relation to employment and working life. Company employees also fulfill all legal requirements within the scope of their activities and comply with legal regulations.

2. Ermoda Textile human resources policies and practices ensures that all recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc.and all other applications are fair.

3. Discrimination between employees within the organization due to language, race, color, gender, political thought, belief, religion, sect, age, physical disability and similar reasons is unacceptable.

4. A positive and harmonious working environment is created by supporting the cooperation in the company and the conflict environments are prevented so that people with different beliefs, thoughts and opinions can work in harmony.

5. Private and personal areas of the employees are respected.

  • Communications between persons cannot be violated by non-parties.
  • It is forbidden to give / disseminate / seize personal data unlawfully, even if it is recorded in accordance with the law.
  • Personnel information arising from the nature of the business relationship in the workplaces and which may be required in the future shall not be used other than their purpose and shall not be shared with third parties without the consent of the persons.
  • Private and family life of all employees is respected.

6. In addition to all kinds of immunities of employees, physical, sexual and emotional immunities are also protected.

• Any breach of the immunity of employees by physical, sexual and / or emotional harassment in the workplace or in any place where they are employed is contrary to the law and the code of ethics and is not tolerated by the Company in any way. The purpose of this practice is to ensure that employees work in a work environment where physical, sexual and emotional immunity is protected.

  • Violation of a person's body immunity by sexual behavior and / or sexual harassment of a person without physical contact is defined as sexual harassment. According to this; any behavior that may be considered within this definition is prohibited.
  • In addition, those who has a negative behaviour towards the person complained about any harassment or to persons who assist in the investigation of the complaint are also not tolerated.

7. No employee can be entitled to demand privileged treatment, privilege to any person or be subjected to a special treatment due to different sex, religion, language and race. Getting concessions by making use of differences such as gender, religion, language, race cannot be accepted.

8. Workplace physical working environment and conditions are ensured to be healthy and safe for all employees.

 

III. LEGISLATION TO BE APPLIED

If the application of the regulations in the country and / or countries where the work will be performed is likely to create adverse results in terms of ethical values adopted by Ermoda Textile, we should try to find solutions within the ethical rules and procedures we have.

 

IV.        RESPONSIBILITIES OF EMPLOYEES

ER-ETHICS and related policies and procedures set out the ethical rules on how we should behave and how we should do our business. Compliance with these rules is the primary responsibility of all employees. In this direction, all Ermoda Textile employees have the following responsibilities;

  • Acting in compliance with laws and regulations in all circumstances,
  • To read the Ermoda Rules of Business Ethics, to know, understand, internalize and act in accordance with the rules, principles and values ​​included in it,
  • Learning the general and specific policies and procedures applicable to the company,
  • Consultation with the manager and human resources about potential violations of himself or others,
  • Promptly report potential violations of himself or others; communicating these issues to the manager, human resources and /or the Ethics Committee in written or verbally, with or without anonymity,
  • To follow “Methods and Procedures for Ethical Decision Making” defined to help act in accordance with the rules and solve problems,
  • Collaborating with the Ethics Committee in ethical investigations, keeping information about the investigation confidential

 

A. Methods and Procedures for Ethical Decision Making

As a guide in deciding an action plan, you should follow these steps and ask yourself these questions:

1. Determining the Event, Decision or Problem

  • Have you been asked to do something that you think may be wrong?
  • Are you aware of a situation in the company or in your business partners that may be potentially unlawful or that does not comply with business ethics?
  • Are you trying to make a decision and have doubts about how to behave in accordance with the business ethics?

2. Think Before You Make a Decision

  • Try to clearly identify and summarize the problem or question
  • Ask yourself why there is a dilemma
  • Consider options and results
  • Think about who might be affected
  • Consult others

3. Decide on an Action Plan

  • Define your responsibilities
  • Review all relevant facts and information
  • Consult appropriate company policies, procedures and professional standards
  • Evaluate the risks and think about how you can reduce
  • Try to create the best action plan
  • Consult others

4. Test Your Decision

  • Review ethical questions
  • Review your decisions based on the company's core values
  • Ensure that you follow company policies, laws and professional standards.
  • Consult others and evaluate their views within the planned action plan.

5. Continue Stably

  • Share your decision including justification with the people concerned
  • Share what you've learned
  • Share your success story with others

 

B.  4 Basic Questions to Consider

1. Does this activity / behavior comply with laws, rules and traditions? (Standards)

  • Does it meet professional standards?
  • Is it legal?

2. Is this activity / behavior balanced and fair? Would we be uncomfortable if the competitor (someone else) did it? (Sense of justice)

  • Is it right for you?

3. Would our company and stakeholders feel uncomfortable if all the details of this event were heard by the public? (Emotions and ethical values)

  • Would you be embarrassed or remain in difficult situation if others knew you were doing this?
  • Can it have negative consequences for you or your Company?
  • Who else may be affected (other employees within the Company, you, shareholders, etc.)?

4. To what extent does "reality to be perceived" coincide with "objective reality"?

  • How would it reflect in the newspapers?
  • What would a reasonable person think under the same conditions?

 

V. RESPONSIBILITIES OF EXECUTIVES

Ermoda Textile managers have additional responsibilities beyond the responsibilities defined for employees within the framework of ER-ETHICS. Accordingly, managers are responsible for;

  • Ensuring the creation and maintenance of a company culture and work environment that supports ethical rules,
  • Being an example to the implementation of ethical rules with their behaviors, to educate employees about ethical rules,
  • Supporting employees in communicating their questions, complaints and notifications regarding ethical rules,
  • Providing guidance on what to do when consulted, taking into account all notifications and, when deemed necessary, forwarding them to the Ethics Committee as soon as possible,
  • Ensuring that the business processes under its responsibility are structured in a way that minimizes risks related to ethical issues and applying necessary methods and approaches to ensure compliance with ethical rules.

VI. RESPONSIBILITIES OF ETHICAL RULE CONSULTANTS

Ethical Rule Consultants are responsible for:

  • Directing and advising on questions and issues raised by employees in ethics within the company,
  • Directing the nonconformities to the Ethics Committee that cannot be resolved within the company or requiring an investigation,
  • Contributing to the resolution of the internal ethical nonconformities requested by the Ethics Committee,
  • Reporting the ethical questions and nonconformities to the Ethics Committee on a regular basis or upon request,
  • Being a contact person from the company in the investigations conducted by the Ethics Committee and providing the necessary support to the investigations,
  • To monitor the effectiveness of ER-ETHICS practices carried out in the Company; support in applications.

VII. OTHER RESPONSIBILITIES

  • Company top management is responsible for the effective implementation of ER-ETHICS or the Rules of Business Ethics specific to their company that they may form within this framework and they should create a culture supporting these ethic rules.
  • The Rules of Ethics and all related policies are reviewed, revised and documented by the Human Resources Department with the recommendations of the Ethics Committee and announced to the company with the approval of the Chairman of the Board of Directors.
  • Company Human Resources is responsible for providing the employees with information about the Rules of Ethics and providing training in certain periods in order to ensure the understanding of the policies and rules and ensuring the continuous communication of this issue with the employees.

 

Company management is responsible for the following issues in cooperation with the     Ethics Committee:

• Ensuring the confidentiality of complaints and notifications made within the framework of the Rules of Ethics and protecting individuals after their notifications,

• Ensuring the safety of the employees who report,

• Ensuring the timely, fair, consistent and sensitive investigation of complaints and notifications and decisively taking necessary actions towards violations

VIII. SETTLEMENT OF NON-COMPLIANCES WITH RULES OF ETHICS

Those who violate the Rules of Business Ethics or Company policies and procedures will be subject to a variety of disciplinary sanctions, if necessary, that may result in them being asked to leave. Disciplinary sanctions will also be applied to persons who approve, direct, or have knowledge of improper acts that violate rules and who do not make the necessary notification appropriately.

 

A. Ethics Committee

The Ethics Committee is responsible for investigating and resolving complaints and notifications that the ethical rules have been violated under the Ermoda Textile Business Ethics Rules (ER-ETHICS). The Ethics Committee, which reports to the Chairman of the Board of Directors of Ermoda Tekstil, consists of the following persons:

President - Cavidan AKKAN

Member - Ali OKTAY

Member - Sinan AKKUŞ

 

B. Ethics Committee Working Principles

The Ethics Committee conducts its activities within the framework of the following principles:

  • Keeps it confident,  the identity of those who make a notification or complaint, as well as notices and complaints.
  • Conducts the investigation as confidentially as possible.
  • Has the authority to request information, documents and evidence directly related to the investigation from the existing unit. The committee may examine any information and documents only limited by the subject of the investigation.
  • The investigation process is recorded in official report from the beginning. Information, evidence and documents are added to this report.
  • The report is signed by the chairman and members.
  • The investigation is dealt with promptly and the result is reached as quickly as possible.
  • Decisions taken by the Committee is implemented immediately.
  • The relevant departments and authorities are informed about the result.
  • The chairman and members of the Committee act independently and unaffected by the department managers and the hierarchy within the organization while performing their duties on the issue. No pressure or suggestion can be given to them.
  • The Board may seek expert opinion if it deems necessary and may benefit from the experts by taking measures that will not violate confidentiality principles during the investigation.hareket ederler. Kendilerine konu hakkında baskı ve telkin yapılamaz.