1. Purpose

The purpose of the Anti-Bribery and Anti-Corruption Policy is to establish anti-bribery and anti-corruption policies to prevent bribery and corruption.

2. Scope

Anti-bribery and anti-corruption policy includes;

• All Ermoda Textile employees, including the Ermoda Board of Directors,

• The companies and employees from whom we receive goods and services, persons and organizations (business partners) working on behalf of Ermoda Textile including suppliers, consultants, lawyers and external auditors.

This Policy;

• Is an integral part of Human Resources Practices approved by Ermoda Board of Directors.

3. Definitions

Corruption is the misuse of the authority that is obtained because of the current position directly or indirectly in order to gain any kind of earnings.

Bribery is the request or acceptance of provision, offer or promise of interest, directly or through intermediaries, for the purpose of making, having, performing, not doing, accelerating, slowing down a work related to the performance of its duty; to act in violation of the requirements of the task by means of mediation such as the other person within the framework of an agreement with him or the party requesting it, or to benefit someone else because of this relationship.

Bribery and corruption can take many forms, including:

• Cash payments,

• Political or other donations,

• Commission,

• Social rights,

• Gifts, hospitality,

• Other interests.

4. Duties and Responsibilities

The implementation and updating of the Anti-Bribery and Anti-Corruption Policy are under the authority and responsibility of the Board of Directors. In this context;

  • The Human Resources department advises the Board of Directors to establish an ethical, reliable, lawful and controlled working environment,
  • The senior management evaluates the risks and establishes the necessary control mechanisms in accordance with the principles to be determined by the Board of Directors,
  • In case of failure to comply with policies, rules and regulations, notification, review and sanction mechanisms should be determined and operated.

In addition, all Ermoda Textile employees are responsible for,

• complying with the policies determined by the Board of Directors,

• effectively manage risks related to their field of activity,

• working in compliance with the relevant legal regulations and Ermoda Textile practices.

5. Companies from which Goods and Servies Purchased and Sold and Business Partners

Companies and business partners who purchase and sell goods and services are obliged to comply with the principles of the Policy and other relevant legal regulations, and the work with individuals and organizations that do not comply with them is terminated.


6. Our Policies and Procedures

6.1 Bribery and Corruption

Ermoda Textile is against all kinds of bribery and corruption. It is absolutely unacceptable to take or give a bribe whatever the purpose is.

Business relations with third parties who wish to do business with Ermoda Textile through bribery or corruption should not be maintained.

6.2 Gifts

A gift is a product that does not require a financial payment and is usually given for thanking or commercial courtesy by persons or customers who have a business relationship.

Any gift offered or given to third parties by Ermoda Textile must be publicly offered in good faith and unconditionally.

The same principles are applied for the acceptance of the gifts and should not be accepted except for symbolic gifts that do not have high material value. In addition, even if it is within this scope, the acceptance of gifts should not be frequent and the acceptor should notify the HR and senior management of the company through his first supervisor.

6.3 Facilitation Payments

Facilitation payments are not offered to persons or entities covered by this Policy to secure or expedite a routine transaction or process (obtaining permits and licenses, obtaining

7. Error-free Record Keeping

The issues that Ermoda Textile has to comply with accounting and registration system are regulated by legal regulations. According to this;

  • All accounts, invoices and documents related to relations with third parties (customers, suppliers, etc.) are recorded and maintained in a reliable, complete and accurate manner,
  • There should be no distortion of the accounting or similar commercial records of any transaction and the facts should not be distorted.

8. Education and Communication

The Anti-Bribery and Anti-Corruption Policy has been announced to Ermoda Textile employees and is continuously and easily accessible through Ethics Line.

Trainings are an important instruments for raising the awareness of employees. In this context,  Human Resources department designs training programs in which all employees must attend to.

9. Notification of Policy Violations

If there is an opinion or doubt that an employee or a person acting on behalf of Ermoda Textile is acting contrary to this policy, it should be conveyed to the Human Resources and Social Compliance Officer via Ethics Line.

Ermoda Textile promotes an honest and transparent approach; It supports any employee who expresses his sincere concerns in good faith or a person acting on behalf of Ermoda Textile and keeps the notifications confidential. The information of the employee making the notification is not included in the documents or processes. No employee that has notified an Ethic Rule violation to Ethics Line cannot be subject to pressure or punishment due to the notification.

If the notifier is subjected to such treatment, he or she must forward it to the Ethics Committee.

The company or business partners from whom goods and services are purchased should also regularly remind their employees about the Ethics Line and encourage them to notify if they encounter such situations. This is also guaranteed by contracts.

10. Policy Violations

In cases where it may be contrary to the policy, the matter is reviewed by the Ethics Committee and the necessary sanctions are applied in case of inappropriate behavior.

In the agreements made with the companies on behalf of Ermoda Textile, where the goods and services are purchased and sold, if it is determined that there is a behavior, attitude or activity contrary to the Policy, the provisions stating that the works / current contracts can be terminated unilaterally by Ermoda Textile and in case of a policy violation, these provisions apply without exception.