We Focus on Embracing Sustainable Responsibilities.
1. Introduction
At CCN Holding and its Group companies, we strive to be a good corporate citizen in everything we do.
For this reason, we have brought together our existing operating principles under a unified Corporate Social Responsibility (CSR) framework policy.
The principles set out in this policy cover all areas of our operations, have been developed in line with relevant corporate governance principles and international standards, and are regularly reviewed and updated accordingly.
Our Boards and Committees support the principles defined in the relevant guidelines, rules, and standards, translate them into a set of guidelines and standards that establish a common approach across the Group, and turn them into a practical guide for our on-site managers and employees.
2. Compliance, Monitoring, and Reporting
We continuously monitor compliance with these policies, and the Board regularly reviews the results.
Each local manager is responsible for ensuring that this policy is communicated to all employees, properly understood, and effectively implemented within their areas of responsibility.
Employees who have a reasonable suspicion of a violation of this policy must report it to their immediate supervisor, senior management, or through the reporting mechanisms established within the Holding.
No form of retaliation, reprisal, or harassment against employees who report in good faith is tolerated, and disciplinary action is taken against anyone engaging in such behavior.
The Board does not make any criticism or take issue with any loss of business resulting from adherence to the principles of this policy.
3. Code of Business Conduct
3.1. General Statement
This Code of Business Conduct defines the standards expected from the employees of CCN Holding and its Group companies in all internal and external relationships with colleagues, customers, stakeholders, and third parties.
3.2. Fundamental Code Standards
• We conduct our business with honesty, integrity, and transparency in every respect, showing respect for human rights and for the interests of our employees, customers, and third parties.
• We respect the legitimate interests of third parties.
• We uphold the highest standards of integrity, never promise more than is reasonable, and do not make commitments we cannot keep.
3.3. Employees
a) We foster a workforce built on mutual trust and respect—free from any form of bullying, mobbing, or harassment—where everyone feels responsible for the Company’s performance and reputation.
b) We respect individuals’ rights, customs, and traditions, as well as their freedom of association and right to unionize, and we engage in good-faith dialogue with duly elected employee representatives.
c) In line with the Equal Opportunity Policy, we conduct recruitment and promotions based on objective criteria and the qualifications and competencies required for the position.
d) We maintain strong communication with our employees through our information and consultation procedures.
e) We support our employees in realizing their potential by providing appropriate training and development opportunities.
f) We respect the privacy of our employees’ personal data.
g) We fairly reward employees for their contributions to the company’s success.
h) We operate mechanisms that enable the secure reporting of legitimate concerns about corruption and ensure that no one is victimized for reports made in good faith.
i) We provide the necessary information and training to ensure compliance with this Code and the related policies.
j) We strive to protect employees from third-party exploitation that may compromise their safety, health, or well-being.
3.4. Business Integrity
• We build our relationships with suppliers, stakeholders, and other parties on mutual trust, understanding, and respect.
• We expect those we do business with to adhere to business principles consistent with our own.
• We carry out our operations in accordance with fair competition principles and applicable regulations.
• Accounting and other records must accurately and honestly reflect the nature of transactions; no unrecorded accounts, funds, or assets shall be maintained.
• We comply with all applicable laws and regulations wherever we operate and seek legal advice whenever necessary.
• We review and monitor our business risks, including social and environmental risks.
• We do not facilitate, support, or tolerate any form of money laundering activity.
3.5. National and International Trade
• We engage in fair and ethical competition within the framework of competition and antitrust laws and do not obstruct others from competing fairly with us.
• We comply with all export control laws and sanctions when conducting business worldwide.
3.6. Personal Conduct
• All employees are required to act in compliance with this Code of Business Conduct.
• Company assets (buildings, vehicles, equipment, cash, procurement cards, etc.) must be protected and not misused.
• Emails, internet, information systems, and telephones must be used for business purposes only, in accordance with this Code and relevant IT policies.
3.7. Bribery
• No employee or anyone acting on our behalf shall give or accept any bribe, facilitation payment, or other improper payment.
• This rule applies to all transactions worldwide with public officials and private individuals or entities, including any payments made or received, whether directly or through a third party.
• The Group ensures the establishment, effective communication, and implementation of adequate procedures to prevent the risk of bribery.
3.8. Gifts, Entertainment, and Improper Payments
• Gifts or entertainment exceeding USD 150 that are designed to influence business decisions or may give such an impression shall not be accepted or offered.
• No employee shall offer, give, solicit, or accept any form of kickback, incentive, or improper benefit.
• In case of any doubt, the employee must consult their immediate supervisor or the Group HR Director.
3.9. Conflicts of Interest
• We respect employees’ privacy; however, all employees are expected to refrain from any personal relationships, activities, or financial interests that conflict with their responsibilities toward CCN Holding and its Group companies.
• Employees or consultants shall not seek to obtain any benefit for themselves or others by misusing their position or the Company’s resources or assets.
• All actual or potential conflicts of interest (including close relatives and/or shared interests) shall be disclosed to and discussed with the relevant department head.
• Price-sensitive information shall never be disclosed to any unauthorized third parties under any circumstances.
3.10. Confidentiality
• Information obtained during employment shall not be used for personal gain or for any purpose other than its intended use.
• Confidential information obtained during business processes shall always be respected.
3.11. Occupational Health and Safety
• We are committed to creating and maintaining a safe and healthy working environment for our employees, customers, and communities.
3.12. Environment
• We are committed to continuous improvement in managing our environmental impact.
• All employees are expected to comply with local environmental management systems and support the improvement of environmental performance.
3.13. Customers
• We are committed to providing our customers with safe, high-quality, consistent, accessible, reliable services that deliver value for money.
• Employees are expected to act respectfully and honestly in their relationships with customers and public officials.
• In particular, we protect the well-being of vulnerable groups and uphold the highest standards of personal conduct in relationships requiring trust.
• Customer Service: Keeping our promise is one of our core values. Our commitment is to deliver safe, reliable, customer-oriented, innovative, and sustainable services.
3.14. Supply Chain
• We work with an extensive supplier network to deliver our core services; therefore, strong supplier relationships are at the heart of our business.
• While procuring competitive goods and services, we strive to ensure that they do not originate from sources that endanger human rights, safety, or the environment.
• We expect our suppliers to adopt and implement safety, environmental, product quality/management, labor, human rights, social, and legal standards in compliance with our Supplier Code of Conduct.
• We strive to develop long-term relationships that benefit both parties in line with our quality, environmental, performance, and sustainability targets and objectives.
3.15. Social Engagement
• Due to the nature of our operations, we engage with all segments of society in the regions where we operate.
• We are committed to strengthening good relationships with these communities and building social partnerships for positive change.
3.16. Implementing the Code of Business Conduct
• The Corporate Governance Board is the highest decision-making authority in the implementation of this Code.
• The Corporate Audit Department resolves any implementation or interpretation issues that cannot be resolved at regular audit levels under the oversight of senior management.
• The Human Resources Department implements the applicable rules and procedures for full compliance and ensures that all employees, suppliers, subcontractors, and consultants know, understand, and apply them.
• Employees who require further information may contact the Human Resources Department.
4. Employment
4.1. Equal Opportunity and Diversity Policy
The Board is committed to equal opportunity in the delivery of public services and as an employer.
The objective of this Policy is to ensure the fair, equitable, and consistent treatment of employees, customers, contractors, and all other individuals or entities that interact with CCN Holding and its Group companies.
Senior Managements of the Group companies are responsible for ensuring the following:
a) Creating a productive and healthy working environment that promotes diversity and inclusion;
b) Actively promoting and making the diversity policy and its practices visible;
c) Developing new initiatives to enhance the engagement of employees, contractors, and customers;
d) Demonstrating continuous improvement in diversity and equal opportunities.
4.2. Regulations and Codes of Practice
This Policy complies with international regulations and the applicable codes of practice in the countries where CCN Holding and its Group companies operate.
The Policy is continuously monitored to ensure compliance with supplementary regulatory requirements and aims to go beyond those requirements whenever possible.
4.3. Recruitment
All recruitments are carried out in a fair, equitable, and consistent manner for all candidates.
Recruitment practices are inclusive, and barriers to employment are removed within the framework of applicable regulations.
4.4. Personnel Training
To become both an inclusive employer and an inclusive service provider, guidance and training are provided to raise awareness and strengthen equity and diversity.
4.5. Human Rights
The Human Rights Policy lies at the core of CCN Holding and its Group companies.
a) All employees are treated fairly and honestly regardless of their place of duty, mutually agreed conditions are provided, and appropriate training for the required job skills is delivered.
b) Fair wages reflecting local market conditions are paid, and the national minimum wage requirement is met at all times.
c) Working hours shall not be excessive and shall comply with sector guidelines and applicable national standards.
d) Employment is freely chosen. Practices such as unlawful child labor, forced or bonded labor, and compulsory overtime shall not be used, nor tolerated.
e) Anti-discrimination laws and regulations are complied with in the countries where the Group companies operate.
f) Practices such as physical punishment, psychological or physical coercion, or verbal harassment shall not be used nor tolerated; disciplinary procedures shall apply where required.