We embrace a business culture founded on the principles of transparency and responsibility.
At CCN Group, we carry out all our operations on the principles of honesty, integrity, responsibility, trust, and respect, and invite our employees and business partners to act in accordance with these values.
Our Ethical Principles and Policies apply across all levels within the Group and establish a common standard of conduct in our business relationships.
1. Ethical Guidelines Implementation Framework
• Our Ethical Principles and Policies define how to act in accordance with applicable laws and company procedures.
• Our employees are expected to adhere to these principles in their daily work and report any suspected incidents or violations.
• The policies apply to the Board of Directors, Senior Management, all employees, and the Group’s business partners.
2. Ethical Principles and Policies
2.1. Anti-Corruption and Anti-Bribery
• Corruption and bribery are strictly prohibited.
• We do not accept any extra payments for services and maintain a zero-tolerance policy toward improper payments.
• All our interactions with public officials are recorded accurately and completely.
2.2. Anti–Money Laundering
• We do not tolerate any form or activity related to money laundering.
• We conduct mandatory third-party due diligence for all customers and business partners and report any suspicious cases to the relevant departments.
2.3. Political Contributions and Relationships
• We do not make any monetary or in-kind contributions to political parties or candidates on behalf of the Group.
• We do not use any corporate resources for political purposes.
2.4. Social Responsibility, Donations, and Sponsorships
• We carry out social responsibility and donation activities strictly in accordance with established procedures.
• We do not accept any contributions that could harm the Company’s reputation, lack transparency, or aim to gain advantage through public officials.
2.5. Gifts and Entertainment Expenses
• Gifts and entertainment may be accepted only within the limits set out in the established procedures and at a reasonable level.
• We report any gifts received from third parties to the Board within three days.
• We do not give gifts to public officials.
2.6. Conflict of Interest
• We avoid any situations where our employees’ personal interests conflict with the Company’s responsibilities.
• Any business relationships or financial interests involving relatives must be reported to the Ethics Board.
2.7. Combating Unfair Competition
• We avoid any practices that could lead to unfair competition in our relations with competitors and third parties and ensure full compliance with competition laws and regulations.
2.8. Third-Party Due Diligence
• We assess all third parties we work with for their compliance with ethical principles through due diligence.
• We verify whether they meet the criteria of financial soundness and independence.
2.9. Privacy and Data Security
• Confidential information is protected and must not be disclosed to unauthorized parties.
• We process personal data in compliance with our information security procedures and applicable laws.
2.10. Insider Trading
• We do not use non-public information for commercial gain.
• All forms of insider trading are strictly prohibited.
2.11. Diversity and Equal Opportunity
• We apply a zero-tolerance policy toward all forms of discrimination and harassment.
• We provide equal opportunities for all employees and support diversity.
2.12. Fair Working Conditions
• We provide a safe, healthy, and respectful working environment for our employees.
• All forms of child labor and forced labor are strictly prohibited.
2.13. Occupational Health & Safety and Environment
• We regard workplace safety and environmental awareness as fundamental elements of our operations.
• Our employees are responsible for reporting any unsafe conditions in the workplace.
• We comply with all environmental regulations in our projects.
2.14. Legal Responsibility
• We comply with all applicable laws and regulations in every country in which we operate.
• Our employees are required to consult the Legal Department in any situations involving potential legal risks.
3. Whistleblowing and Reporting Practices
• Reporting ethical violations is a corporate responsibility.
• All employees and stakeholders may report any violations or suspected cases to the Ethics Board via e-mail at etik@ccngroup.com.tr.
• Our employees are protected against any form of retaliation for reports made in good faith.
The Ethics Board investigates the reported cases and, when necessary, takes action in cooperation with the Disciplinary Board.
All codes of conduct regarding anti-corruption, conflicts of interest, confidentiality, fair working conditions, third-party relations, occupational health & safety, environmental standards, and reporting procedures are detailed in the linked document.