Privacy Policy

1. General
   
   

Tectone Tecnoloji Sanayi ve Ticaret Anonim Şirketi, hereinafter referred to as Tectone, has adopted the principle of protecting the privacy of visitors to its website.

In this context, as Tectone, we take all necessary measures and actions to comply with the provisions of the European Union Data Protection Regulation on the Protection of Personal Data No. 6698 ("GDPR") in order to process personal data in accordance with the law.

We would like to inform you about what kind of information about users is processed by Tectone and how it is used. We will also inform you how you can exercise your respective rights as a data subject.

Possible changes regarding this Privacy and Cookie Policy will be published on this page. Within this framework, you will be provided with up-to-date information on what information is stored and how this information is used.

This Privacy and Cookie Policy does not apply to other websites linked to from the Tectone site.

2. Collection, use and processing of personal data
   
   

Tectone uses the personal data in order to make this website available to users and to ensure the proper functioning of this website and the necessary level of security. Any processing of the data outside this scope takes place on the basis of other legal obligations, bans, where Tectone has a legitimate interest or with the express consent of the user concerned to Tectone.

Tectone stores and processes the relevant data specifically for the following purposes:

Tectone automatically collects and stores certain data when users visit the website. This data includes The IP address or device ID assigned to the respective end device, which is required to transmit the requested content (e.g. in particular content, texts, images and data files provided for download, etc.), the activity of the users in the context of the website, the type of end device concerned, the type of browser used and the date and time of use.

Tectone stores this information for 7 days in order to detect and monitor misuse.

At the same time, Tectone uses this information to improve the provision of services, their features, functions and general management tasks.

In addition, Tectone l deletes or anonymizes the data in use, including IP addresses, without undue delay when such data is no longer required for the purposes set out above.

The processing and use of the relevant data is carried out on the basis of the relevant legal provisions that allow this to be done, where (1) the processing is necessary for the provision of the website; or (2) Tectone has a legitimate interest in ensuring and improving the functionality and smooth operation of the website, as well as its suitability for the needs of users.

Recipients of the collected data may include members of the responsible internal departments, other companies affiliated with Tectone, external service providers (e.g. hosting and content management, marketing agencies, other third-party providers if required for the services they provide), relevant authorities within the framework of their respective obligations and powers, e.g. if required in the event of a formal request or to establish, exercise or defend Tectone's rights, and current shareholders or, in the event of a sale, merger or acquisition, future shareholders of Tectone companies.

3. Purposes of Processing Personal Data
   
   

Contact (Contact Us) / Customer Request Form

You may have shared your contact information with us via our call center numbers in the relevant tab on our website.

We will use your data to respond to your request.

The processing and use of your data is carried out on the basis of the provisions of the law and/or Tectone's legitimate interest, which allows this to be done if the processing is necessary to meet your current request.

 In the event that you have not given your consent for a longer period of time by means of any express declaration of consent, we will only retain the data for the period necessary to fulfill the objective given above or for the period required by any legal retention obligation.

4. Cookies ("Cookies"), Pixels, and similar technologies
   
   

This website uses cookies and similar technologies. Cookies are small units of data that are necessary to use our website and are temporarily stored on your hard disk by your browser. A cookie usually contains a unique identifier, consisting of a randomly generated number, which is stored on your device. Some of these identifiers expire when your website session ends, while others may remain on your device for longer periods of time. Technically necessary cookies will be used automatically. Other cookies (or similar technologies) will only be applied upon your prior consent.

There are different types of cookies. First-party cookies are placed by the website visited and can only be read by that website. Third-party cookies are placed by other organizations from which we receive services for various services we use. For example, we use external analytics service providers who place cookies on our behalf to identify content that is liked or disliked on our website. In addition, the website you visit may contain embedded content from a source such as, for example, YouTube, and cookies may also be set by that source.

A pixel is typically a transparent image measuring only 1 pixel x 1 pixel that is placed on a website for the purpose of personalizing content or making the browsing experience more efficient and easier, and collects certain data such as IP address, browser type, access time, or preset cookies. They are often used in conjunction with cookies as pixels create and manage cookies.

If you give your consent, the website will collect information about the device's operating system, browser, installed fonts, IP address, plug-ins and more detailed information. In this way, the device can be re-recognized for marketing purposes relating to the user.

Management’s Commitments

TECTONE TECHNOLOGY Senior Management;
Demonstrates leadership and commitment to the Quality Management System through

• Accountability for the effectiveness of the Quality Management System,
• Ensuring that quality policy and quality objectives are established and that they are aligned with the strategic direction and context of our organization,
• Ensuring that the requirements of the quality management system are integrated into the internal processes of our business,
• Promote the use of process approach and risk-based thinking,
• Ensuring that the resources needed for the Quality Management System are available,
• Ensuring that the Quality Management System achieves its intended outputs,
• Recruitment, guidance and support of people who will contribute to the effectiveness of the Quality Management System,
• Promoting improvement,
• Supporting other relevant management officials to demonstrate leadership (as applied to their areas of responsibility).

Code of Conduct On Combating Bribery and Influence Peddling

Can Holding Tectone Group has adopted the principle of conducting its activities with ethics and integrity in all countries where it operates, in compliance with all applicable laws.

In particular, this aspiration is manifested in our unwavering commitment to prevent and detect any risk of bribery and influence peddling that the Group may face in the course of its activities.

Accordingly, Can Holding Tectone Group maintains a zero-tolerance policy on bribery and influence peddling. Every employee within Can Holding Tectone Group, in all relationships with private and public partners, or involving third parties, must be aware that such practices are inconsistent with our values and the way Can Holding Tectone Group conducts its business.

Therefore, all employees are expected to be aware of and comply with our internal standards for the prevention and detection of bribery as set out in the Code of Conduct.

1. What is the purpose of the Code of Conduct to prevent and detect bribery and influence peddling ?

Bribery distorts market movements to the detriment of organizations and people, simultaneously harming the economy, sustainable development and the efficiency of international trade.

In addition to the detrimental impact on the economy, the commission of bribery or influence peddling activities can have extremely serious civil (criminal and criminal) and financial consequences, and those found guilty of such violations can damage a company's reputation and business. In this context, judicial authorities are taking an increasingly strict approach to punishing not only companies but also their employees for bribery and influence peddling activities.

For all these reasons, Can Holding Tectone Group prohibits all forms of bribery and influence peddling by its employees, regardless of their position or geographical location. In particular, this formal prohibition is linked to Tectone's commitment to the United Nation's Global Compact, which establishes the fight against bribery as a universal principle.

There are different situations in which Can Holding Tectone Group may be exposed to any risk of bribery and/or influence peddling. The extent of this risk varies depending on various factors such as the nature of the service provided (project management, project management office (PMO), etc.), the field of activity, or even the geographical location of the place of supply.

This Code of Conduct for the prevention and detection of bribery and influence peddling (Code of Conduct) takes into account the following to enable our employees to deal with situations that pose a risk of bribery.

• Describes the rules to be followed by all employees in the different situations specified;
• Contains suggestions and recommendations on the attitudes and behaviors that should be adopted to handle such situations;
• Draws the attention of employees to the signs that require their vigilance; and
• It sets strict prohibitions for certain behaviors.

2.Who is the Code of Conduct addressed to?

The Code of Conduct applies to all employees of Can Holding Tectone Group, regardless of their geographical location, whether in Turkey or outside Turkey.

Compliance with and enforcement of the rules set forth herein applies to everyone within the scope of their duties and responsibilities.

The Code of Conduct applies wherever Can Holding Tectone Group conducts its business in and outside Turkey. Every legal entity (subsidiary or controlled company) belonging to Can Holding Tectone Group must ensure that the Code of Conduct is followed.

Everyone must be vigilant, not only for themselves but also for those around them, in their team or under their responsibility.

Any employee who has a question or doubt about the application of this Internal Code may, at any time: - Intranet, in particular:

• Policy to Prevent and Detect Bribery and Influence Peddling, Gifts and Invitations Policy,
• Sponsorship and Patronage Policy,
• Internal Warning Policy,
• Refer to internal policies, including those related to the Third Party Assessment Policy.

- Can directly contact the Legal and Compliance Department of Can Holding Tectone Group:

tectone.com.tr/contact

3.What is bribery and influence peddling?

3.1 Bribery

"Active" bribery is defined as the act of offering to provide an unfair advantage to a person in order to induce that person to do (or refrain from doing) something in connection with his or her duties, or the act of offering to comply with the person's requests (in order to obtain the relevant benefit).

"Passive" bribery is defined as the act of soliciting or accepting an unfair advantage for a person to do (or refrain from doing) something in connection with his or her duty, or to do something to facilitate the performance of that duty.

An act of bribery may also be involved in the following cases:

• The beneficiary acts through a third party (partner, intermediary, subcontractor, etc.),
• The person in interest is not the ultimate beneficiary,
• The fraudulent conduct and the act of obtaining unfair advantage do not occur at the same time; or
• The realization of an unfair advantage in forms other than the payment of money (services rendered, objects of material value, etc.).

Influence trading

Active "influence peddling" is defined as the act of offering to provide a person with an unfair advantage or to comply with the person's requests (with a view to obtaining the relevant benefit) by abusing one's influence (real or presumed) in order to get a public official or institution to make a favorable decision in favor of the person providing the benefit.

"Passive" influence peddling is defined as the act of soliciting or accepting any benefit from a person in exchange for a public official or institution abusing its influence (real or assumed) to secure a favorable decision in favor of the person providing the benefit.

4.Attitudes and behaviors expected from employees

4.1 Basic rules to be followed

In general, you should avoid doing the following:

• Providing, offering, promising anyone (customers, suppliers, partners, public legal entities, etc.), directly or through a third party, any benefit, gift, invitation or anything of material value that would or could be perceived as an inducement or voluntary act in terms of bribery or influence peddling.
• Solicit or accept, directly or through a third party, any benefit, gift, invitation, or anything of monetary value that could be perceived or perceived as an inducement or voluntary act in terms of bribery or influence peddling; and
• Authorizing or engaging a third party intermediary (e.g. agent, representative, etc.) in the performance of your duties, where their integrity has not been reviewed and confirmed in accordance with applicable due diligence procedures and without a proper contract in place.

4.2 Questions to ask in a risky situation

All employees who are confronted with a "risky" situation in terms of bribery and influence peddling are asked to ask the following questions

• Are relevant laws or regulations being complied with?
• Is the intended action appropriate in terms of the Code of Conduct?
• Is the action in question free from personal gain?
• Would I be embarrassed if I heard about the action in question?

4.3. Things to watch out for

In general, you should be alert to the following situations:

• Certain signs originating from or directed to third parties (repeated or luxurious invitations, valuable gifts, unusual invoices or commissions, emails transmitted through a personal account, etc.); or
• Incentives (promises of personal or professional benefits) or pressure (threats of professional retaliation) to obtain an unusual benefit (disclosure of confidential information, favoritism towards a third party, etc.).

4.4. Good habits

When you encounter these signs and potential risks, you should take the following actions:

• Report your suspicions, concerns and worries, consult quickly with your immediate supervisor and the Legal and Compliance Department and, if necessary, exercise your

• Consult with the Legal and Compliance Department if you have questions or doubts about the lawfulness of any practice; or

• Not taking the intended action if you are at risk of being directly or indirectly involved in a bribery or influence peddling activity.

5.Examples of bribery and influence peddling

5.1 Any unfair advantage

Principle :Bribery involves offering, promising or providing, directly or indirectly, a benefit to a person, usually by inducing him or her to abuse his or her position or authority, in order to obtain an unfair advantage in return or to secure a favorable decision. An unfair advantage can take many different forms and may include, but is not limited to, the following actions in particular

• Payment of money;
• Receiving a discount or refund;
• Contracting for services; or
• Hiring a person as a trainee, on an indefinite-term employment contract or on a fixed-term employment contract.

The assessment of these benefits as acts of bribery or influence peddling depends on the context in which the benefits are provided or promised.

Attitudes and behaviors to adopt

Your customer has forwarded you a CV of one of his/her acquaintances who is looking for an internship or job opportunity within the Tectone Group.

You may agree to forward the CV to the Human Resources Department or related departments and indicate to the sender and recipient that the CV will be evaluated according to the standard procedure for recruitment and will not be subject to any preferential treatment in this regard.

Signs to be vigilant

You have received confidential information from a third party regarding a call for tenders by an important client. You have been told this information in order to influence your decision on a subsequent assignment to the forwarder. The third party has indicated that you can use their links to get more information.

You should inform your immediate supervisor and the Legal and Compliance Department to get their perspective on this sensitive issue, which may give the impression of unfair advantage.

Prohibited attitudes and behaviors

Upon signing a contract in a foreign country, a client asked you to organize a trip to Turkey to visit your facilities and stay in a luxury hotel with family members.

Upon signing a contract in a foreign country, a client asked you to organize a trip to Turkey to visit your facilities and stay in a luxury hotel with family members.

5.2 Gifts and invitations

Principle : Soliciting, receiving, offering or giving, directly or indirectly, gifts, invitations or benefits of any kind is prohibited. However, depending on the circumstances, gifts or invitations of low value and in accordance with the applicable rules of courtesy may be accepted as long as they are not interpreted as an inducement to offer or obtain an unfair advantage in return or as compensation for an unfair advantage already provided.

The risk of bribery in relation to gifts and invitations is particularly high when the recipient is a public official. We recommend that you always consult with the Legal and Compliance Department before sending or promising anything to a public official.

For more information on our applicable Internal Rules on gifts and invitations, employees are encouraged to refer to the Preventing and Detecting Bribery and Influence peddling, Gifts and Invitations Policy.

Attitudes and behaviors to adopt

You plan to send a new year's gift to a customer or invite them to an event that may or may not be sponsored by Tectone Group.

You must ensure that the invitation or gift complies with the Preventing and Detecting Bribery and Influence Peddling, Gifts and Invitations Policy. If in doubt, you should consult your immediate supervisor.

Signs to be vigilant

An employee of your customer with whom you have had a long-standing business relationship has invited you to a sporting or cultural event that would be costly for the customer (e.g. airfare from the company account).

This invitation poses a high risk of being considered an unfair advantage. You should consult your immediate supervisor and, if necessary, the Legal and Compliance Department before responding.

Prohibited attitudes and behaviors

As a call for tenders for an important customer is approaching, you plan to invite an employee of the customer involved in the call for tenders to a luxury restaurant. At the same time, you want to offer this employee a bottle of wine of a high value as part of the invitation.

Such behavior is likely to be characterized as an act of bribery and is consequently officially prohibited.

5.3 “Facilitation" payments

Principle : "Facilitation" payments are low-value payments or benefits to public officials or civil servants intended to facilitate or expedite routine bureaucratic procedures. Such payments are prohibited

Attitudes and behaviors to adopt

A foreign government agency demanded that you pay fees as part of an administrative judicial procedure. The fees were set in an official document issued by the administration and, as a result, appeared to be a legal and ordinary act

In the above case, it is ensured that you have made a correct payment. However, if in doubt, you should report the matter to your immediate supervisor and the Legal and Compliance Department.

Signs to be vigilant

You have received an email from a Turkish or foreign public official with whom you have been in contact as part of a certification file, sent from a nonprofessional personal email account, asking you to recontact him or her on a private line.

You must inform your immediate supervisor and the Legal and Compliance Department as soon as possible. This is unusual behavior and may be an attempt to put pressure on you to make a facilitation payment to obtain the requested certificate.

Prohibited attitudes and behaviors

An employee of a foreign competent authority responsible for the issuance of a certificate asked you to make a payment to a legal entity for the purpose of facilitating the issuance of the requested certificate, without producing any documents from the authority that could be treated as evidence. He stated that he would try to use his influence to expedite the issuance of the certificate in question.

You must refuse to pay this amount and inform your immediate supervisor and the Legal and Compliance Department as soon as possible. This is a request for facilitation payment, which is a completely prohibited practice.

5.4 Sponsorship, patronage/political contributions and donations

Principle : Any political contributions from the Can Holding Tectone Group's own resources are prohibited. In contrast, legitimate charitable donations and sponsorship are permitted in principle, provided that the transaction meets the following conditions

• Legal in terms of the relevant applicable law;
• Compliant with the Sponsorship and Patronage Policy of the Can Holding Tectone Group (you can consult this policy on the Intranet);
• Formalized and documented (identification of the beneficiary and the use of the donation/sponsorship/donation);
• It must be clearly and specifically registered in the company account of the relevant legal entity of the Can Holding Tectone Group.

Can Holding Tectone Group must ensure that these transactions are not used to conceal practices that could be characterized as bribery or influence peddling. Any sponsorship, patronage or political contributions or donations, etc. requested from Can Holding Tectone Group must be systematically analyzed in a manner consistent with Can Holding Tectone Group's Sponsorship and Patronage Policy.

In this respect, charitable contributions are not allowed in the context of a call for tenders or commercial or financial settlement involving persons linked to the beneficiary, or if the contribution is requested in cash. Special attention should also be paid to charitable contributions made to organizations linked to public authorities or to clients or potential clients (who may be, for example, executives), as well as to requests or suggestions for charitable contributions made by clients or potential clients; these requests require careful review and approval by the Legal and Compliance Department. 

Attitudes and behaviors to adopt

A local public official has asked you to contribute to the benefit of a political party as part of your professional activities.

If necessary, you should refuse to make political contributions, noting that such contributions are prohibited by Tectone's Code of Conduct on preventing and detecting bribery and influence peddling, which is in effect.

Signs to be vigilant

A mayor requested a charitable contribution or sponsorship for the benefit of a local sports association.

Particular caution is required when this request comes from a public official. You should consult with your immediate supervisor and the Legal and Compliance Department, and then, with their assistance, determine the underlying objectives of the request to ensure that the request is not for self-interest and that such a charitable contribution would be appropriate.

Prohibited attitudes and behaviors

One of your colleagues, after using his contacts in a risky country to make you stand out in the negotiations for a contract of high commercial value, asked you to provide a "reward" through a foundation he had set up ostensibly for environmental purposes.

Given the scope of this request, you must refuse to take this action and notify your immediate supervisor and the Legal and Compliance Department as soon as possible.

5.5 Contacting the service provider or third party intermediary

Principle : The use of external providers is common and necessary in certain circumstances (consultants, subcontractors, suppliers, lobbyists, etc.). However, in certain circumstances this may be used as a way to conceal bribery activities: High payments for services provided or overstated invoices may raise suspicion of a hidden kickback. With regard to this risk, an external intermediary or service provider should be consulted in the following circumstances:

• Pursue a real purpose (the benefit is directed to a real need of the relevant legal entity or project of Can Holding Tectone Group and is in return for a fee consistent with the services provided);
• Undergo an integrity and bribery risk check before establishing a business relationship, as part of an assessment procedure (due diligence), the degree of which varies depending on the risk map;
• After establishing a business relationship, be subject to monitoring for the risk of bribery and influence peddling, depending on the degree of risk identified at the time the relationship was established; and
• Documentation of the nature of services and payments.

It should be noted that the procedure for assessing third parties applies in particular to all third parties with whom Can Holding Tectone Group has a business relationship, including customers or even partners within the framework of a joint venture. The procedure ensures that the integrity of the third party is verified and, where necessary, monitoring measures are taken. The degree of the determinations made varies, in principle, depending on the risk posed by the legal entity, as defined by the risk mapping.

For more information on this procedure, employees can refer to the Third Party Assessment Policy available on the Intranet. 

Attitudes and behaviors to adopt

Before engaging a third party service provider, you need to be particularly vigilant and ensure that appropriate due diligence has been undertaken in the selection of the service provider. In particular, you should verify the reputation, background and professional competencies of the third party and ensure that these are documented and archived

Signs to be vigilant

You are considering engaging a consultant for a Project Management Office (PMO) service to be provided to a foreign client. The client has mentioned that they know a consultant who can help you.

Such advice may be concealing a fraudulent agreement between the client and the advisor. You should inform your immediate supervisor and/or the Legal and Compliance Department to help you bring an appropriate resolution.

Prohibited attitudes and behaviors

You have authorized a company to identify a potential acquisition target. The company has requested a payment from you that does not correspond to the standards and requires the payment to be made to an open account of a bank located in a country where banking secrecy applies (e.g. Switzerland, Monaco, Liechtenstein, etc.) or in a location other than the company's domicile, or has not provided adequate disclosure.

You must refuse to take this action and notify your immediate supervisor or the Legal and Compliance Department as soon as possible.

6. Accounting records, documentation and archiving

Principle. Each legal entity of the Can Holding Tectone Group must ensure management and accounting traceability of the records of the different actions and payments performed. This oversight must be transparent, accurate and sufficiently detailed to prove the legitimate nature of the transactions and to avoid any suspicion of concealment of acts of bribery or influence peddling.

Documents showing the nature of the services and actions concerned, including the findings made during the implementation of the procedure for assessing third parties and the identification information of contractors and beneficiaries, should be kept.

For more information, employees are encouraged to refer to the Preventing and Detecting Bribery and Influence Peddling, Gifts and Invitations Policy document available on the Intranet.

Human Resources Policy

Tectone Human Resources Policy adopts a participatory and value-creating Human Resources Management approach with the principles of change and transformation within its vision, mission, competencies and ethical values. It is aimed to create awareness in every employee by providing a fair, transparent, efficient, healthy and development-oriented working environment that supports gender equality. Within the framework of the principles of equality and inclusiveness, discriminatory elements based on all individual characteristics such as gender, age, marital status, religion, language, ethnic origin, pregnancy status or possibility in all practices such as training, promotion, performance management, career management and remuneration, starting from the recruitment process, and all attitudes and behaviors that may harm human dignity such as corporal punishment, physical/psychological pressure, insult and ill-treatment in disciplinary practices are completely opposed.

In all written and verbal communication within and outside the company, an egalitarian and inclusive communication language is used that supports skills and competencies. Acts with a sense of social responsibility to prevent the employment of persons under the age of 18 and/or child labor as required by law, legislation and regulations. In accordance with its working principles,

Except for short-term extraordinary business conditions, it takes care not to exceed the working hours stipulated in the legal legislation. In recruitment processes, priority is given to female candidates among male and female candidates with equal qualifications. Women employees in decision-making positions in middle and senior management, encouraging women employees to return to work after childbirth and preventing possible losses in their career development, representation of women in jobs, professions and sectors traditionally dominated by men and more men in jobs, professions and sectors traditionally dominated by women, ensuring work-life balance and equal sharing of the unpaid workload in the household between women and men, including childcare, and related paternity (including fathers as parents taking an active role/responsibility in child care and development) are supported

A fair remuneration system that is in line with competition and market conditions, sensitive to the principles of equality and fair remuneration system is pursued based on level structures and competencies. Based on the principle of equal pay for work of equal value, all rights of employees are protected. By implementing a fair, transparent, inclusive and equitable performance evaluation system that measures knowledge, experience, effort and behavior, it is ensured that system outputs form the basis of development and promotion processes. The career paths of all employees are managed with the principle of development orientation, and employees are included in personal, technical and vocational training programs in line with their development needs. Students are encouraged to gain experience in professional development by offering internship programs.

Incentives are provided to increase the motivation of employees and strengthen their loyalty to the organization with the findings obtained from practices carried out for employee satisfaction across Group companies. The Company emphasizes the importance of balancing the private and professional lives of employees through the effective implementation of policies and procedures on work-life balance.

Attitudes and behaviors to adopt

You have received an invoice from a supplier. The way the invoice is presented seems unusual to you (it is not printed on commercial letterhead and does not include details of services performed).

You must return the invoice to the sender and request that a proper invoice be sent..

Signs to be vigilant

You have doubts about an invoice that does not correspond to a service performed or possibly over- or under-calculated. In addition, your supervisor has asked that this transaction not appear in email conversations or copies.

You must inform your immediate second line supervisor and the Legal and Compliance Department as soon as possible.

Prohibited attitudes and behaviors

1) You are under a lot of pressure from your line manager to terminate a contract with a client for whom you have not completed due diligence. There are also a number of indicators (investigations already carried out, geographical area, etc.) that suggest that the counterparty poses a bribery risk.

2) You are under a lot of pressure to pay even though you have noticed that a particular supplier's procurement procedure was ignored or not followed.

In these two cases, you must refuse to carry out the action and notify your immediate second line supervisor and the Legal and Compliance Department as soon as possible.

7. Conflicts of interest

A conflict of interest arises when an employee has a personal interest that may affect his or her professional judgment and the impartial performance of his or her duties and responsibilities.

Can Holding Tectone Group employees must avoid any situation that creates or could create an actual, apparent or potential conflict between their personal interests and the interests of the group. An employee's personal interest includes any benefit, monetary or non-monetary, provided for him/herself or his/her parents, friends, relatives, persons or organizations with whom he/she has a business or friendship relationship.

Attitudes and behaviors to adopt

If an employee decides that he or she has a potential or proven conflict of interest, he or she must report it to his or her immediate supervisor or the Legal and Compliance Department. If the employee is in doubt about a potential conflict of interest, he or she should consult a supervisor or the Legal and Compliance Department, who will advise him or her to avoid risky situations in order to safeguard both the Group's and his or her own interests.

8. Internal Warning System

Can Holding Tectone Group makes available to all employees an internal alert system that enables them to report in good faith a violation or risk of violation of an anti-bribery law, regulation or a rule in this Code of Conduct. Alerts are processed by the Group's Legal and Compliance Department to be managed confidentially.

You should also report such a warning to other internal and standard warning reporting channels, such as a supervisor, human resources and personnel representatives, if necessary.

Can Holding Tectone Group will not tolerate any retaliation against an employee who makes a good faith report or assists Can Holding Tectone Group in investigating a proven or alleged violation reported through the internal whistleblower system. However, anyone who knowingly or maliciously sends a false or misleading warning will be subject to criminal penalties.

For more information on this alerting system, employees are encouraged to consult the Internal Alert Policy document available on the Intranet.

9. Penal sanctions for non-compliance with the Code of Conduct

Compliance with the Internal Rules contained in the Code of Conduct is mandatory. In other words, if an employee fails to comply with these rules, the employee is subject to disciplinary action, without prejudice to any judicial proceedings that may be initiated by the company.

It is also stated that any action taken in violation of a law aimed at combating bribery and influence peddling may result in criminal sanctions for the employee concerned.

Appropriate penalties and proceedings will be those prescribed for the relevant employee by applicable law and will be conducted in accordance with applicable legal procedures. In particular, such penalties may include dismissal for misconduct and claims for damages, at the discretion of Can Holding Tectone Group.

Occupational Health and Safety Policy

As TECTONE TEKNOLOJİ, our Occupational Health and Safety Policy is based on respect for human beings and the environment in which they live.

Occupational Health and Safety (OHS) is the first priority in every area where TECTONE TEKNOLOJİ operates. In order to ensure a safe and healthy working environment, everyone is obliged to do what is necessary within the limits of their authority. One of our most important goals is to protect all our employees and the environment we are in against the possible risks of our line of business.

In this direction;

• In the workplace and its annexes; to take all kinds of measures, to have tools and Personal Protective Equipment in accordance with the OHS legislation in force and other requirements related to OHS in order to ensure the health and safety of employees, subcontractors, contractors, visitors and our company personnel working outside the workplace,
• To identify and eliminate unsafe situations and movements that may cause occupational accidents and occupational diseases in the workplace and its annexes, possible accident risks in advance by conducting an effective risk assessment,
• To train our employees in the field of occupational health and safety and to ensure that they achieve a good occupational health and safety awareness,
• To ensure that subcontractors, contractors and visitors serving in the workplace also comply with the rules regarding occupational health and safety set by TECTONE TEKNOLOJİ,

As TECTONE TEKNOLOJİ, we are committed to making it an exemplary company in terms of OHS practices, both within the sector and in the region, before the affiliated institutions, chambers of industry and associations, as our OHS policy.

As TECTONE TEKNOLOJİ, our Occupational Health and Safety Policy is based on respect for people and the environment they live in.

Occupational Health and Safety (OHS) is the first priority in every area where TECTONE TEKNOLOJİ operates. In order to ensure a safe and healthy working environment, everyone is obliged to do what is necessary within the limits of their authority. Protecting all our employees and the environment we are in against the possible risks of our line of business is one of our most important goals.

As TECTONE TECHNOLOGY, our Occupational Health and Safety Policy is based on respect for people and the environment they live in.

Occupational Health and Safety (OHS) is the first priority in every area where TECTONE TECHNOLOGY operates. Everyone is obliged to do what is necessary within the limits of their authority to ensure a safe and healthy working environment. Protecting all our employees and the environment we are in against the possible risks of our line of business is one of our most important goals.

In this direction

• In the workplace and its annexes; to take all kinds of measures, to have tools and Personal Protective Equipment in accordance with the applicable OHS legislation and other requirements related to OHS in order to ensure the health and safety of employees, subcontractors, contractors, visitors and our company personnel working outside the workplace,
• To identify and eliminate unsafe situations and movements that may cause occupational accidents and occupational diseases in the workplace and its annexes, and possible accident risks in advance by conducting an effective risk assessment,
• To train our employees in the field of occupational health and safety and to ensure that they achieve a good occupational health and safety awareness,
• To ensure that subcontractors, contractors and visitors providing services in the workplace also comply with the rules regarding occupational health and safety determined by TECTONE TEKNOLOJİ,

As TECTONE TEKNOLOJİ, in accordance with our OHS policy, we are committed to making it an exemplary company both in the sector and in the region in terms of OHS practices before affiliated institutions, chambers of industry and associations.

Corporate Social Responsibility Policy

This Corporate Responsibility Policy has been prepared to ensure that TECTONE TEKNOLOJİ personnel act in the best interests of the company and fully comply with the ethical rules determined according to company values, responsibilities and priorities. The Code of Ethics covers all TECTONE TEKNOLOJİ employees.

2.Application

2.1 Additional Work

It is a private matter for the personnel to evaluate their time outside of business hours. However, TECTONE TEKNOLOJİ does not allow its personnel to engage in practices that may affect their performance and harm their work.

2.2 Benefit

"benefit" is defined as a gift, gratuity, any service that has monetary value.

1. a. No personnel or relatives of personnel should have a relationship with competitors, suppliers or any other company with which business is conducted in which they can benefit directly or indirectly.
2. b. Personnel must not be the owner or partner of a competitor or the owner or partner of a private company that will do business with TECTONE TECHNOLOGY.
3. c. No employee may directly or indirectly ask another company that his/her company works for to perform unpaid work on behalf of himself/herself or his/her acquaintances.
4. d. Company information, products and programs may not be used for personal benefit or made available to third parties.

2.3 Gifts and Gratuities

1. a. Personnel may not accept money, sample products or a gift that is not commensurate with their salary on their behalf from any person or organization that does or wants to do business with TECTONE TEKNOLOJİ.
2. b. Personnel are obliged to report suspicious situations to their manager.
3. c. Gifts received on holidays and New Year's Eve are considered to have been received by the company. How these gifts will be used is determined by the General Directorate.
4. d. Dinner invitations from business partners may be accepted if the content is related to the business.

2.4 Unlawful Behavior

Personnel who engage in the following behaviors shall be dismissed immediately:

1. a. Coming to the workplace with weapons, explosives or flammable materials.
2. b. Removing property not belonging to the person from the workplace without written permission from the department manager.
3. c. Knowingly and willfully damaging the property of the company or company personnel.
4. d. Misleading, altering, destroying or destroying company reports or records, or assisting someone else to do so.
5. d. Being a member of illegal organizations.

2.5 Improper Use of Confidential Information

1. a. Every employee must be aware that all financial and commercial information concerning TECTONE TECHNOLOGY is proprietary and confidential.
2. b. Such information is never discussed outside the framework of the assignment.
3. c. No personnel other than the person(s) authorized by the company may provide information about the company to any member of the media or interview them on these matters.
4. d. Trade Secrets and Proprietary Information

All kinds of commercial, professional and technical information that the personnel learn due to their work and duties in the workplace are considered "confidential". Company personnel are prohibited from providing information to third parties without being authorized by the Senior Management on the following matters.

• Every employee must be aware that all financial and commercial information concerning TECTONE TECHNOLOGY is proprietary and confidential.
• Such information is never discussed outside the framework of the assignment.
• No personnel other than the person(s) authorized by the company may provide information about the company to any member of the media or interview them on these matters.
• Trade Secrets and Proprietary Information

Code of Ethics Procedure

1. PURPOSE:

This Code of Ethics Procedure sets out the implementation standards of the rules of conduct that must be followed by all employees, regardless of their expertise, qualifications and position, in order to improve the reputation of Tectone Teknoloji Sanayi ve Ticaret A.Ş. in its commercial and other economic activities.

The norms of the Procedure regulate the situational behavior of employees in accordance with the principles of morality, honesty, justice and partnership required for the successful operation of the Company.

2. SCOPE AND RESPONSIBILITY

Our code of ethics is an important element for both the success of our Company and personal success. Creating an environment in accordance with ethical principles in all departments of our company is the responsibility of our managers. In this context, our managers,

• Accepts the importance of our ethical principles and the laws and regulations that our Company is subject to and adheres to them under all circumstances.
• Sets an example for its employees with its behavior and thoughts.
• Adopts the implementation of ethical principles in our Company as its top priority responsibility.
• It works to establish the company culture and to ensure that employees adopt the norms and values that they must abide by.
• Creates an environment where his/her teammates do not hesitate to bring ethical issues to him/her, as well as problems that may arise in all operations of the Company, and establishes open communication.
• Always acts consistently in their behaviors and decisions. It covers employees at all locations of Tectone Teknoloji Sanayi ve Ticaret A.Ş. Human Resources and Department Managers are responsible for the implementation of this procedure.

3. DEFINITIONS

• 1. Costs of representation: The cost of the official reception and/or reception of representatives of other companies participating in negotiations in order to establish and (or) maintain reciprocal relationships.
• 2. Business ethics: It is the set of rules that regulate the relationships that arise in the process of business communication.
• 3. Corporate culture: Values, beliefs, traditions and norms of moral behavior that are mandatory for all employees of the company and determine their behavior.
• 4. Company resources: Tangible and intangible resources, including people, machinery, materials, tools, intellectual property, reputation, information and information resources, documents, communication tools and communication channels, software and cash that the company owns and employs for its activities.
• 5. Confidential information: Any state secret with restricted access in accordance with the legislation of the Republic of Turkey. means information that does not contain any information and has limited access.
• 6. Conflict of interest: Situations arising from activities, interests or relationships that will affect or are considered likely to affect the interests of the Company by Company employees.

USE OF COMPANY RESOURCES

The protection of Company resources against theft, wasteful use or use for personal benefits and personal purposes is ensured through the interactive work of Company employees, specially established units within the Company for these purposes and security units.

In order to ensure the efficient use of the Company's resources, each employee is required to (but not limited to) the following

• 1. To do his/her best to prevent wasteful use, theft and use of Company resources for personal purposes,
• 2. Use communication and communication facilities (telephone, internet connection, e-mail, etc.) only for Company business to use for related purposes,
• 3. Trade secret normatives in force within the Company and in accordance with the legislation of the Republic of Turkey all electronic programs, data, contact information and written documents to third parties. protect against access by third parties,
• 4. Use Company resources, employees and assets in accordance with the legislation.

The Company does not exclude the possibility that employees may, in certain circumstances, be required to use electronic communications facilities, office equipment and assigned office vehicles for purposes other than Company business.

In accordance with the legislation of the Republic of Turkey, the Company has the right to demand compensation from the employee for the damages incurred by the Company due to the violations of the aforementioned.

4.1. Representation Costs

• 1. Representation expenses are used for clients and business meetings.
• 2. Representation expenses are used only in the areas to which they relate and cannot be switched between expenditure areas.
• 3. For the expenditure for which an invoice is not received, an invoice is not obtained from elsewhere. If necessary, an expense voucher is issued in accordance with the law and expenditures are not concealed by obtaining different invoices.
• 4. Managers are not allowed to create team spirit, reward, increase motivation, etc. can buy gifts for their employees, take them out to dinner, to the theater, to concerts and so on. This No discrimination is made between employees in the realization of activities.

4.2 Time Management

Time is one of the most important resources of the Company. Company employees are required to use their working hours efficiently and not to spare time for their personal affairs during working hours. Managers may not assign their employees for their personal affairs. It is the responsibility of the organizer of the meeting to ensure the effectiveness of the time allocated for the meeting and it is essential that all participants come to the meeting prepared. All participants respect the start and end times of the time allocated for the meeting.

It is essential that no private visitors are accepted during working hours, and in special and exceptional cases, the meetings of employees with external visitors should not exceed 10-15 minutes.

5. RELATIONSHIPS

5.1. Relations with Suppliers

The following points are taken into consideration in relations with suppliers. Tectone Teknoloji Sanayi ve Ticaret A.Ş. employees conduct their activities in an ethical and honest manner under all circumstances and conditions, and ensure that human rights upholds human rights principles aimed at promoting and protecting human rights, protects the environment contributes to society. All of our employees act in accordance with the Ethical Principles and Rules governing our relations with Company suppliers.

5.2 Relations with Customers

Tectone Industry and Trade Inc. is based on customer satisfaction, their needs and prioritize customer demands and respond to customer complaints and demands in the shortest time and in the most accurate way. We work with an understanding that gives. Even if it is in favor of the company, customer weaknesses cannot be exploited and profit cannot be sought by providing incomplete or incorrect information.

• 1. The reporting of customer complaints to senior management is meticulously carried out by the relevant units within the principles of transparency.
• 2. Employees may not enter into a private business relationship with a customer of the Company, borrow money or lend money to the customer. money cannot be given.
• 3. Purchasing goods or services from a customer for a fraction of their value or for no consideration at all is considered as procurement of interest and requires disciplinary action up to and including termination of the employment contract.

5.3 Relations with the Media

Giving statements to any media organization, giving interviews, participating in seminars, conferences and similar events as a speaker and determining whether a fee will be received in return is subject to the approval of the General Manager. Under no circumstances can personal gain be derived from these activities.

5.4 Relations with Public Authorities

Relations with public authorities are carried out within the framework of laws and Company policies/procedures. Official A written record is created for the information requested by the authorities and the General Manager/Legal Counsel's Office/Related Directors are kept informed. Information is provided to those concerned accurately and on time.

6. OBLIGATIONS TO THE COMPANY

6.1 Accepting Gifts, Invitations, Aid and Donations

6.1.1 Gift Acceptance

No gifts may be requested or implied from customers, suppliers and consultants. No gift, money, check, property, free vacation, special discount, etc. that will put the company and the area under obligation vested interests are unacceptable.

However;

1. Gifts that are highly likely to adversely affect customer relations if not accepted may be accepted provided that a senior manager is notified.

2. Gifts that, if accepted, will not affect the financial decision to be taken may be accepted provided that a senior manager is notified. Gifts that do not meet the specified criteria shall be rejected by an appropriate method.

6.1.2. Acceptance of Invitations; invitations for meals, business meetings and social activities made by third parties that do not affect the decisions of the personnel participating in the invitation, do not contradict the Company's policies and interests; may be accepted provided that the approval of a senior manager is obtained.

6.1.3. Acceptance of Aid and Donations; No person who has any kind of account relationship with the Company and donations and grants cannot be accepted from the organization. Proposed donations and grants shall, in any case, be shared with the senior manager.

6.2. Not engaging in activities that may create a conflict of interest

Conflict of interest is the inverse relationship between the Company's interests and personal and inter-customer interests. Personal interests cannot be prioritized over Company interests. Position within the Company, Company property, service information cannot be used for personal interests.

When there is a conflict of interest or when there is any doubt about whether there is a conflict of interest in any matter, the situation is shared with a senior manager.

It is not appropriate for our employees to purchase services and materials from our suppliers for their own special needs at better prices and conditions than the prices and conditions received by the Company or in a way that exceeds their own needs and reaches commercial dimensions.

This situation shall be clearly stated in the proposals made by the Companies in which the members of the Former Company are directly/indirectly shareholders or employees and in all kinds of transactions made with these Companies and the approval of the Board of Directors shall be obtained.

In the event that the employees of the Supplier Companies and the employees of the customers are close relatives, these relationships are not allowed to create a conflict of interest. In such cases, the approval of the Board of Directors is obtained before establishing a commercial relationship.

Employees authorized to make purchasing decisions; family members, close relatives or friends in the bids submitted by the Companies in which it is directly or indirectly a shareholder, the purchase decision they do not. Provided that this situation is clearly stated in the evaluations, that it is in the Company's interest and that the Board of Directors is informed and approves this matter, a purchase decision may be made.

Except for our employees who are in contact with customers and suppliers as part of their job, it is not appropriate for other employees to be in close contact with these persons.

Employees of Tectone Teknoloji Sanayi ve Ticaret A.Ş,

• Cannot obtain any special benefits from customers, establishing an intermediary relationship between customers cannot transfer benefits.
• In case of conflict of interest between customers, treats all customers equally and fairly.
• Endeavors to perform their duties impartially.
• In order to prevent conflicts of interest, personnel are obliged to comply with the following rules.
• Not to act as sureties for customers and not to accept their sureties.
• Not to enter into relationships with customers that are incompatible with professional practices such as debt-credit relationship etc,
• Not participating in invitations or domestic/international travels that are fully or partially paid for by customers, except with the knowledge and permission of a senior manager,
• Not accepting uncustomary gifts from customers of a nature and value that may give rise to liability for them,
• Not to give overly expensive gifts to existing or potential customers and not to provide advantages (e.g. special discounted shopping opportunities) that are within the customer's business area but exceed the purpose and go beyond normal practices.

6.3. Doing Business Outside the Company

Employees cannot engage in activities that require them to be considered as merchants, tradesmen or self-employed persons, cannot be a shareholder in companies (excluding share purchases from companies traded in capital markets through stock exchange for the purpose of utilizing savings). In all kinds of companies and commercial enterprises, alongside merchants or tradesmen cannot hold any paid or unpaid position. Except for the Company's subsidiaries and affiliates, the Board of Directors of other Companies he/she cannot be a member of the Board.

Assignments in institutions and organizations such as cooperatives, professional chambers, unions, professional and social associations, foundations, federations and confederations, etc. that are related to the Company's activities or that operate for social purposes are made with the approval of the General Manager.

Provided that employees with expertise do not interrupt their work, they may attend professional conferences, universities and vocational teaching in their schools is subject to the permission of the General Director.

6.4. Workplace and appearance rules

Workplaces, production and administrative facilities must be organized in accordance with occupational health and safety and fire safety rules, ergonomically, aesthetically and in a way that does not interfere with work functions.

Employees who do not receive work clothes and shoes due to their position are not obliged to dress in a single style. However, dress should be modest and customary, appropriate to the work environment.

6.5. Political Activities

Company personnel, on behalf of the Company or on their own behalf, even within the financial means of the Company, may not be financially and financially involved in political activities. cannot provide moral assistance. They cannot be an active member of any political party during their term of office.

Managers cannot ask their employees to do political work or become a member of a party

6.6. Discrimination

Discrimination based on age, language, race, health status, gender and marital status
rules. The company may terminate the employment contract of those who violate these rules.

6.7. Personal Aid and Donations

Company employees may personally provide material or moral aid or make donations to third parties outside the Company. They may take part in aid organizations provided that they inform the Human Resources Directorate.

7. GENERAL RULES

All our employees,

• 1. Protection of the trademark,
• 2. To comply with the principle of professional confidentiality,
• 3. To protect the personal data of employees, customers, suppliers and other business partners required by its business,
• 4. Honestly fulfill their duties,
• 5. To ensure that company assets are meticulously protected,
• 6. It is obliged to comply with legal regulations and all policies and regulations published by the Company.

Employees are obliged to fulfill the instructions given by their superiors. However, if any employee believes that the instruction received is contrary to the legal regulations and/or all policies and regulations published by the Company, the rules of ethics or the manner of application of these rules, he/she should report this situation to his/her supervisor in a higher position than the one who gave the instruction and/or via e-mail to the e-mail address specified on ethical principles. Such an action may, for any reason whatsoever, be taken by the notifying does not put the staff in the position of accusers.

7.1 Protection of the Trademark

Tectone Teknoloji Sanayi ve Ticaret A.Ş. brand is our most important value from which we draw strength in all our activities. Our primary goal is to protect and enhance the strong reputation of our brand consistently in line with our marketing and communication principles. While fulfilling their duties, our employees must protect the reputation of our brand and adopt the principle of raising the status of our brand.

We recognize that personal social media accounts are everyone's private spaces and we respect their sharing preferences. However, we expect that social media accounts should be made with personal e-mails other than e-mails with the Company extension; that our employees refrain from sharing content that may cause disputes, uncertainties or represent the Company in their use of social media; and that they do not share information and photos that may violate privacy rules.

7.2 Professional Confidentiality

Our employees are under the obligation not to disclose any information about the Company's activities and transactions to anyone other than the legal authorities and authorized Company employees, which are clearly listed in the laws. Our employees who become aware of confidential and/or first-hand Company information that has not been disclosed to the public during the performance of their duties in internal activities may not disclose the confidential information they have learned to anyone other than those who need to learn such information.

"Confidential information" includes all kinds of Company information that our employees learn in writing or verbally or through electronic media due to their duties, and that is old, current or may be acquired in the future. Employees may only disclose confidential information that they have knowledge of due to their duties to other Company employees who are obliged to learn confidential information within the framework of Company policies and regulations; they may not disclose to third parties. Disclosure of the secrets of our Company to anyone other than the authorities expressly authorized by law in this regard is considered as a violation of our ethical principles.

The Company owns the analyses, plans and all kinds of non-public or publicly disclosed information prepared for and belonging to the Company. The Company also owns the Company's financial data, services, capacity reports, computer software, expenditures, business plans, customer and supplier names, working and marketing methods, announcements, internal regulatory documents and information in the form of regulations and instructions. This information is relevant cannot be disclosed to unauthorized persons.

7.3 Protection of Confidential Information

Necessary measures are taken to ensure the confidentiality, storage and non-disclosure of information belonging to the Company.

• Tables are cleared every evening and confidential documents, if any, are locked and keys are kept in a safe place.
• Passwords and user codes are kept confidential and not disclosed to anyone.
• No information other than business and legal obligation notifications is copied to diskettes and similar devices.
• Persons who are not Company employees are not allowed to access the Company's information network or perform transactions on Company computers.

7.3.1 Implementation of Legal Rights of Employees

The Company recognizes labor rights arising from the law as an integral part of human rights. The Company conducts activities in accordance with all legal rights of employees, their right to be honored when they achieve successful results, stands against discrimination, forced labor and mobbing, and supports employee participation in decisions made for the development of the Company.

The Company implements personnel development programs for employees, including training and professional development, social packages, motivational methods, working and resting conditions.

The Company supports practices that strengthen employee loyalty, discipline, productivity and traditions of working in teams.

7.4 Internal Corporate Culture

7.4.1. Personal relationships within the company

All employees have the right to work in an environment of respect and understanding. The relationship between company employees should be based on mutual respect and be based on obedience and loyalty in the context of subordinate-superior relationships. Dialogue between employees must be in a manner that does not offend the honor and dignity of the other person.

7.4.2. Relations with companies with which the Company has business relations

Company employees must maintain maximum objectivity and impartiality in their relations with other companies and must make every effort to conduct these relations within the framework of the principles of justice, mutual respect, ethical codes of conduct and the legislation of the Republic of Turkey.

Company employees may not hide, change or misuse any information for personal benefit through the Company or other companies with which the Company has a relationship.

7.5. Compliance with Legal and Company Policies and Regulations

The first priority of Tectone Teknoloji Sanayi ve Ticaret A.Ş. employees is to comply with legal regulations and Company policies and regulations and to avoid incidents that may cause risks. Our employees never abuse their duties and do not allow them to be abused. Misconduct is the use of one's authority and responsibility for one's own benefit and thus harming the Company and our business partners. Company employees may not directly or indirectly participate in disgraceful crimes such as theft, forgery, pickpocketing, or condone others to do so.

All Company employees, in the event that they witness behaviors contrary to our code of ethics, should report the situation to their immediate supervisor and/or via message to the e-mail address specified in the code of ethics.

8. RESPONSIBILITIES UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA

In our company, the Personal Data Protection Law No. 6698 (KVKK), which was prepared in accordance with the EU General Data Protection Regulation (GDPR) and implemented in our country, is applied. As Tectone Teknoloji Sanayi ve Ticaret A.Ş., we show a very respectful attitude towards the right to obtain information about the personal data of our employees and act in accordance with the law in force. The data subject has been informed about the purpose for which the processed data is received, the conditions under which it can be processed and transferred, and its preservation with the clarification text of our company and his/her explicit consent has also been obtained. In addition, by filling out our company's Application Form, he / she can apply to our company with the specified application methods and can easily use his / her right to obtain information about his / her personal data within the scope of Article 11 of the KVKK. Our company processes and preserves the personal data received from its employees in accordance with Article 12 of the KVKK in accordance with the law. Another reason for receiving personal data is to fulfill its legal obligations. For this reason, it is a responsibility of Tectone Teknoloji Sanayi ve Ticaret A.Ş. for its employees to process these personal data in accordance with the purpose for which they were received. Tectone Teknoloji Sanayi ve Ticaret A.Ş. employees cannot transfer the personal data they obtain as part of their duties to outside parties or share them with third parties unless there is a legal obligation or a work order authorization from the company. The employee undertakes not to leak the personal data obtained by using company resources. It is within the responsibility of the employee that the employee shall not use the personal data obtained by taking it out of the purpose of business progress and disproportionately and shall not cause this. Otherwise, the sanctions specified in the disciplinary regulations of Tectone Teknoloji Sanayi ve Ticaret A.Ş. will be applied to the employee who discloses personal data. In addition, it is obvious that our company will use all legal rights in the event of damage to Tectone Teknoloji Sanayi ve Ticaret A.Ş. by the employee who discloses the personal data acquired as part of his duty.

9. IMPLEMENTATION OF THE CODE OF ETHICS

Those who interrupt Tectone Teknoloji Sanayi ve Ticaret A.Ş.'s ethical conduct and violate the principles of practice may face disciplinary sanctions that may last until the termination of employment contracts.

All our employees must adopt ethical codes of conduct and must not act contrary to these rules.

Compliance with Tectone Teknoloji Sanayi ve Ticaret A.Ş. code of ethical conduct should be questioned in all activities and decisions taken. In case of any doubt about compliance with the code of ethical behavior, the following communication channels should be used. Confidentiality is essential in applications.

Tectone Teknoloji Sanayi ve Ticaret A.Ş Mersin Branch

Mersin Tarsus Organized Industrial Zone Burhan OSB Mahallesi Esra Şemsi Cad. No:1 Akdeniz / Mersin

E-mail: mersin.ik@tectone.com.tr

Quality Policy

Within the scope of the "WHITE WARE PRODUCTION PLANT PROJECT" in which we are active as TECTONE TECHNOLOGY;

• To identify changing demands on time based on the needs and expectations of the interested party (Internal / External Context) and Customer Satisfaction, to respond quickly to demands, to realize and deliver projects on time, to provide quality products / services and competitive prices,
• Continuous, committed support and involvement of senior management,
• Quality management system reflected in every process,
• Developing and monitoring our suppliers,
• Implementation of error prevention methods,
• Ensuring environmental awareness,
• To follow and efficively
• To adopt the understanding that all personnel are responsible for quality, and therefore to instill quality awareness in all personnel, to provide training to improve their knowledge and skills, to encourage harmony and creativity,
• Ensuring the happiness and motivation of the staff,
• To adopt the understanding of continuous improvement of the system through the evaluation of measurable Quality Objectives based on performance indicators of the processes defined in the system,
• To ensure that the necessary work is carried out to assess risks and opportunities that may affect product compliance,
• To comply with national and international standards,

is our quality policy.

In this direction, as TECTONE TEKNOLOJİ, we undertake that we will set our Quality Targets, constantly review our targets and disseminate this policy among all our employees.

Equality Procedure

1. PURPOSE

Tectone Teknoloji Sanayi ve Ticaret A.Ş. values the people it works with and all views and beliefs, including ethnic origin, color, race, gender, culture, age, religion, marital status, sexual orientation, disability, education, opinion, political opinion, way of thinking.

2. SCOPE

This procedure covers all employees working under the roof of Tectone Teknoloji Sanayi ve Ticaret A.Ş. as it is to ensure that all workers and prospective workers, including interns, do not discriminate and are not subjected to discrimination.

3. RESPONSIBLE

Human Resources and Department Managers are responsible for the implementation, announcement and follow-up of this procedure.

4. APPLICATION

"Discrimination" means any distinction, segregation or favoritism based on race, color, sex, religion, political belief, national or social origin which has the effect of nullifying or impairing equality in the acquisition of employment or occupation or in the treatment to be accorded such employment or occupation.

What is Discrimination? According to Article 10 of the Constitution of the Republic of Turkey, everyone is equal before the law regardless of language, race, color, sex, political opinion, philosophical belief, religion, sect and similar reasons. Women and men have equal rights. Measures to be taken for this purpose shall not be interpreted as contrary to the principle of equality. No person, family, group or class shall be privileged.

What is Positive (Affirmative) Discrimination? Positive discrimination in business life is the discrimination made to ensure that groups such as women, young employees and persons with disabilities receive a fair share of the available opportunities. In business life, positive discrimination has been made in laws or regulations in order to provide equal opportunities for women, young and disabled employees. Positive discrimination in business life is the discrimination made to ensure that groups such as women, young employees and disabled people get a fair share of the opportunities available.

Tectone Teknoloji Sanayi ve Ticaret A.Ş. cannot discriminate based on language, race, gender, political opinion, philosophical belief, religion and sect and similar reasons in the employment relationship. Unless there are substantial reasons, the employer may not treat a full-time employee differently from a part-time employee and an indefinite-term employee differently from a fixed-term employee. Lower wages for work of the same or equal value cannot be agreed on the basis of gender.

All personnel working within Tectone Teknoloji Sanayi ve Ticaret A.Ş. and new employees are informed that discrimination is prohibited within the scope of Orientation Training. All personnel submit their complaints about discrimination within the scope of the Wish Complaint boxes and Open Door Complaint Policy. All incoming complaints are kept confidential and recorded.

Tectone Teknoloji Sanayi ve Ticaret A.Ş. cannot discriminate based on language, race, gender, political opinion, philosophical belief, religion and sect and similar reasons in the employment relationship. Unless there are substantial reasons, the employer may not treat a full-time employee differently from a part-time employee and an indefinite-term employee differently from a fixed-term employee. Lower wages for work of the same or equal value cannot be agreed on the basis of gender.

All personnel working within Tectone Teknoloji Sanayi ve Ticaret A.Ş. and new employees are informed that discrimination is prohibited within the scope of Orientation Training. All personnel submit their complaints about discrimination within the scope of the Wish Complaint boxes and Open Door Complaint Policy. All incoming complaints are kept confidential and recorded.

BEHAVIORS INCLUDED IN THE SCOPE OF DISCRIMINATION

• Making inappropriate statements regarding race, gender, color, language, religion, age, nationality, disability,
• Explicit stories, jokes, innuendos or comments.
• In recruitment, promotion, retirement, or other practices, the discrimination of individuals based on language, religion, race, gender, ethnic origin, skin color, disability or physical appearance.
• Asking for information on religion, nationality, political views, sexual orientation, etc. in job applications.

MEASURES TAKEN TO PREVENT DISCRIMINATION

• In cases such as recruitment and promotion, situations such as religion, language, race, age, gender, skin color, sexual orientation, disability cannot be a reason for preference.
• Information such as religion, language, nationality, political opinion, sexual orientation cannot be specified in job postings.

EMPLOYER'S RESPONSIBILITY IN CASES OF DISCRIMINATION

The onus is on the employer to prove to the employee claiming to have been discriminated against that such a violation did or did not exist. The employer shall initiate an investigation into the complaint. It shall take all measures to protect confidentiality in order to allow it to carry out a fair and thorough investigation. The person alleged to have engaged in discriminatory behavior is also given the right to defend himself/herself. After being convinced that discrimination has occurred, the person(s) concerned is referred to the disciplinary board.

PENALTIES TO BE APPLIED

If it is proven that the discriminatory behavior was committed consciously, the employment contract of the person who committed the discriminatory behavior will be terminated.

If it is proven that the discriminatory behavior is unconscious, the person is given a written warning, and if the behavior is repeated, the employment contract is terminated.

If unfounded and malicious discrimination claims are proven, the person(s) claiming to have been subjected to discriminatory behavior shall be given a written warning and the employment contract may be terminated for just cause.

Tectone Teknoloji Sanayi ve Ticaret A.Ş. treats all employees equally without discrimination on the basis of race, color, gender, nationality, age, religion, seniority, marital status, sexual orientation, gender identity, sexual expression, pregnancy, veteran status, disability or any other non-job-related factors, does not discriminate and does not accept discrimination.

Social Compliance Procedure

Our social compliance policy includes the standards that we have created together with all our business partners, based on our core principles and values and created as a result of teamwork.

Our goal is to ensure that the Social Compliance Policy becomes a corporate culture within our organization. For this reason, social compliance standards have been established and started to be implemented. With this policy, in addition to creating products and services that comply with social compliance standards, we are committed to providing employees with all their rights arising from the standards within the framework of the law, complying with occupational health and safety rules, being sensitive to the environment, open and honest communication between employees, and creating a workplace environment that is respected and valued. The social compliance policy is announced to all our employees through trainings or communication channels (bulletin board, website, e-mail group, etc.), our suppliers are informed and our suppliers are evaluated according to these criteria.

Under this policy, against employees who raise concerns, worries and complaints, no sanctions or punitive actions are imposed, and that voicing these concerns and worries suggestion, wish and complaint boxes are used. Employees can share their opinions in the boxes, express their requests, complaints and suggestions openly and these can be reviewed by the Senior Management. Evaluated and necessary improvement activities are carried out for areas open to improvement.

2. SCOPE

• The Social Compliance Policy covers the following components:
• Forced Labor (Voluntary Labor)
• Child Labor Force (Underage Workers)
• Discrimination (Egalitarian Approach)
• Ethical Business Behavior
• Working Hours and Remuneration (Wage / Salary)
• Health and Safety
• Commitment with Society and Stakeholders
• Foreign National Employees
• Rest Days and Holidays
• Recruitment and Employment
• Employment Contract (Employer Contract)
• Work and Worker Discipline
• Environmental Protection

3. RESPONSIBLE

All managers and employees are responsible for implementation.

4. APPLICATION

1. Forced Labor (Voluntary Labor)

Our company cannot impose forced labor on any employee. The working principles in our business are based on voluntariness. If the employee quits the job, the company cannot prevent or postpone it, except for any security reasons. All information of our employees is protected and kept confidential to the extent required by law.

2. Child Labor (Underage Workers)

Child labor is not acceptable in any way in our business. Except for compulsory situations such as interns and trainees, the minimum age determined by national and international laws is taken into consideration.

3. Discrimination (Egalitarian Approach)

Our organization values all its employees and their contributions. It has a deep-rooted commitment to stand against discrimination and ensure equal opportunities. As management, we are committed to maintaining our organization as one free from discrimination or physical or verbal harassment on the basis of race, sex, color, nationality, social origin, religion, age, disability, political opinion or any other status protected by applicable law. The selection of personnel for our business is based on minimum qualifications such as vacant position, education, interests, skills, work experience.

4. Ethical Business Behavior

Our business does not tolerate any form of corruption, fraud, embezzlement or bribery.

5. Working Hours and Remuneration (Wage / Salary)

Our business pays its employees competitive wages according to the industry and local labor market. Our practices are carried out in full compliance with applicable laws and labor agreements on wages, working hours, overtime and fringe benefits. We offer our employees opportunities to develop their skills and capacities and, as far as possible.These efforts are supported by providing opportunities for advancement.

6.Health and Safety

Our business ensures the creation and protection of a safe and healthy workplace environment. The Company aims to ensure the continuity of our employees by minimizing the risk of accidents, injuries and exposure to all kinds of factors that threaten health and by creating a safe, healthy and productive work environment. In our business, care is taken to provide a workplace environment free from violence, harassment, threats, abuse and disturbing conditions. All occupational health and safety rules regulated by legal legislation are applied in our business.

7. Engagement with Society and Stakeholders

Our organization engages with its stakeholders by listening to their views, obtaining information from their views and to connect on the basis of good faith, taking into account their views. In this context, the employee determining the representatives according to the legal legislation and discussing the problems of the employees with the representatives and allows them to submit their suggestions in writing in suggestion boxes. Commits to engage in a dialogue with its stakeholders, where appropriate, on workplace rights issues related to the workplace and within its sphere of influence.

8. Employment of Foreign Nationals (Employment of Foreign Workers)

Foreign national employees to be employed in our enterprise in accordance with our laws. Employment contracts will be drawn up in a language they can understand. All personnel procedures from recruitment to termination will be carried out in accordance with the legal regulations in force. Our company protects the labor rights of foreign workers. Our enterprise does not employ illegal workers.

9. Rest Days and Holidays

Our employees are not deprived of rest and vacation days within the framework of their legal rights.

10. Recruitment and Employment

Open positions needed by the management of our company are determined and employment is carried out by the company management in accordance with the law and within the framework of certain rules (egalitarian approach, leave, wages, vacation, employment contract, etc.).

11. Employment Contract (Employer Contracts)

An Employment Contract is prepared between our company and the person to be employed, in accordance with the workplace and the law and containing the conditions offered to the candidate personnel. A copy of the employment contract is given to the employee in return for his/her signature, and all the rules and regulations required by our business and the job are explained to the relevant personnel through orientation training.

12. Work and Worker Discipline

Disciplinary rules determined by the disciplinary board are applied by our company in order to ensure disciplined work. The Company may not impose wage deduction sanctions in any way to discipline its employees. All our employees carry out their work by acting in accordance with the work rules instructions.

13. Protection of the Environment

We manage the environmental impacts that may arise from all our activities with a sense of responsibility. We identify and implement all kinds of improvement and development activities that will eliminate or minimize environmental impacts and use natural resources in the most efficient way in all our activities. All principles in this policy document are put into practice with the necessary regulations and the level of implementation is audited by the relevant units. We consider the success of our business in social responsibility practices as an important criterion in the evaluation of our company performance. This policy document has been prepared to share with all our employees, stakeholders and business partners a clear commitment that Tectone Teknoloji Sanayi ve Ticaret A.Ş. will fulfill all its responsibilities for a better world and future.