ETHICAL PRINCIPLES AND POLICIES GUIDE
Dear Colleagues,
Since its founding in 2007, CCN has grown into a multi-dimensional organization operating globally in the construction, education, tourism, healthcare investment, international project finance management, architecture & design and management organization sectors.
Fundamentally enabling our company's growth and success have been our core values: integrity, commitment, belonging, and respect. And it is these core values that have made us one of the most trusted brands in the industries in which we operate.
We have formulated our Code of Ethics to reinforce our core values and guide our work. Under the leadership of the Board of Directors and Senior Management members, all of our employees are responsible for understanding and acting in accordance with our Code of Ethics.
We prioritize building healthy and long-term relationships with our business partners. For this purpose, our Ethical Principles and Policy provide guidance to all our employees and business partners (customers, suppliers and other key stakeholders) on how to communicate.
We encourage our employees and business partners to contact the Board Secretariat with questions and concerns regarding our Ethical Principles and policies. In addition, our employees can seek guidance from their superiors and Senior Management. These individuals are responsible for addressing or taking action on concerns or issues brought to their attention.
Any employee who reports a concern or violation will be protected from any form of retaliation through our Whistleblower program (WhistleblowerProtection). If there is a violation, appropriate action will be taken in line with our zero tolerance policy, regardless of the person's title or level within the Company.
As we continue on our journey, I wish you all continued success and thank everyone in our Company for their dedication in adopting our Ethical Principles and Policies.
Murat ÇEÇEN
Board Chairman
1.Our Values
Respect to Human Rights
Code of Conduct and Integrity
Constant Improvement
Fairness
Protection of Environment and Nature
2. ETHICS GUIDELINE IMPLEMENTATION GUIDE
Our Guide of Ethical Principles and Policies reinforces our principles and values and the importance of acting in accordance with laws, regulations and these policies.
Our Ethical Principles and Policies tell us who to contact when we have concerns and questions. Our Ethical Principles and Policies serve as a one-stop-shop, providing information and critical advice on appropriate behavior as a CCN Holding employee, both at work and in the outside world. Our Ethical Principles and Policies have been adopted by our Board of Directors and set the principles that apply to the behavior of every individual within our Company, regardless of title or level.
2.1. Objectives
Our Ethical Principles and Policies establish a common framework for how we are expected to behave and do the right thing. It aims to create a sense of trust among employees, business partners and other key stakeholders.
Our Ethical Principles and Policies strengthen our corporate culture by establishing our values and behaviors. The principles in our Ethical Principles and Policies help us think through challenging questions, encourage consultation, and encourage us to speak up when we have concerns.
2.2. Who is subject to our Ethical Principles and Policies?
Our Ethical Principles and Policies apply to our "employees" at all levels, i.e. our Board of Directors, Senior Management and all other employees.
We expect our business partners, including our customers, suppliers and other key stakeholders, to comply with our Ethical Principles and Policies. We aim to work with business partners who share our values and principles of behavior.
2.3. Responsibility of Our Employees
Our Ethical Principles and Policy aims to assist our employees in making decisions with the right course of action. Accordingly, we expect our employees to strictly comply with our Ethical Principles and Policies and to use it as a guide in their daily work.
It is the responsibility of every employee not to remain silent when they observe a violation of our Ethical Principles and Policies or when they have a concern. Employees who remain silent in such situations may be held responsible for failing to report the violation or raise concerns.
When making a decision that may affect our Company's reputation, employees should ask themselves how their actions may be viewed by Senior Management, superiors, coworkers, suppliers and other key stakeholders.
We expect our employees to handle all Company assets responsibly. We must protect our assets from harm and avoid using them inappropriately. We take the same care for the assets of any third party we work with.
We treat our suppliers with the same professionalism that we treat our customers. We strive to communicate openly, directly and appropriately with our suppliers. We select our suppliers based on objective criteria.
3. ETHICAL PRINCIPLES AND POLICIES
3.1. Anti-Corruption and Anti-Bribery
Corruption refers to obtaining or attempting to obtain a personal benefit or business advantage through illegal or improper means. Corruption may include payments or exchanges of anything of value, including money, gifts and hospitality, with the intent to influence a person/entity/organization to obtain an unfair advantage.
A corruption attempt may occur between an employee of the Company and a person from another company or a government official or a person with political influence. The key factor is that the other party has the authority (or is acting on behalf of someone with authority or influence) to gain an unfair advantage over a competitor.
Bribery is the offer or provision of an inducement or incentive to influence the decisions or conduct of a person/entity/organization.
Our Principles
We prohibit corruption and bribery and maintain a zero-tolerance policy for illegal and unethical behavior.
We do not accept or offer extra payments in relation to the service provided. Facilitating payments to expedite a standard government process or anything of significant value are prohibited.
We do not give or accept preferential treatment to or from anyone, especially where there is a risk of compromising the integrity of our Company.
We will not tolerate any deceptive acts by an employee (Deceptive acts may include, but are not limited to, embezzlement, misappropriation of Company assets and false financial reporting).
We will not hold an employee accountable for refusing to engage in any improper activity or refusing to give or receive a bribe that results in lost business.
We maintain effective accounting practices and internal controls to detect and report violations related to improper payments listed in the Anti-Bribery and Anti-Corruption Procedure. All interactions with government officials or employees or agents of state-owned entities must be fully and accurately recorded.
Before offering any gifts, entertainment or other hospitality, meals, travel expenses, or charitable donations to a government official, we seek prior advice from our Board and Legal Department.
3.2 Anti-Money Laundering
Money laundering is the act of hiding criminal proceeds or legitimizing the true source of those proceeds. Money laundering can be carried out through different transactions, including trade-based laundering, where a company deliberately alters invoices for purchased goods to conceal the movement of money, similar to embezzlement. Another method involves concealing the identity of the true owner of a company through various third parties or other persons.
Our Principles
We do not tolerate money laundering or any other illegal activity.
We do not provide services to or work with any third party that could in any way implicate our employees or our Company in money laundering activities.
We conduct a mandatory Third Party Assessment, including a Money Laundering check, on every existing/potential customer, business partner (including beneficial owners).
We report any suspicion or evidence of money laundering to our Board, Finance and Legal Departments.
We ensure that any suspicion of money laundering activity is reported to the competent authorities, regardless of our relationships with related parties.
3.3. Political Involvement and Relationship
Political contributions are cash and non-cash contributions (networking, concessions, etc.) to a specific political party or political figure. It is prohibited to use Company funds, assets, including intangible assets such as Company relationships, or to receive payments from the Company for personal activities, including contributions to political candidates or parties.
Political affiliation means supporting, endorsing or opposing a particular political position, political party or political candidate or a person of political influence by associating the Company's name and reputation with that person or party.
Our Principles
We do not make any financial / non-financial / political contributions to any political organization on behalf of our Company.
We may express our political views, participate in activities or make contributions outside the business environment, using our own resources and without any association with or reference to our Company.
We do not use the Company's time, funds, facilities or assets for political purposes or contributions without the express written consent of the Board of Directors. We further declare that there will be no conflicts of interest.
We will not use any corporate assets for or in aid of any political organization or agenda.
We are not and will not be affiliated with any political party, political position or persons of political influence.
3.4. Social Responsibility, Charitable Donations and Sponsorships
Social responsibility and charitable donations are our acts of material or non-material support to society, either through a foundation or by developing our own social responsibility projects.
Sponsorship is the activity of providing commercial benefits to our Company in return for a cash or cash equivalent contribution.
Our Principles
Our social responsibility, charitable contributions and sponsorship activities must comply with our Social Responsibility, Charitable Contributions and Sponsorship Procedure.
We only sponsor events and individuals in line with our business and our Company's values. Our priority is to support society in line with our expertise.
We only undertake sponsorship and social responsibility projects that do not harm our Company's reputation and are transparent and accountable.
We do not make charitable contributions to gain or influence an advantage over government officials, to obtain business, to gain an advantage in conducting business, or when the intended use of the recipient is not transparent.
We do not make charitable contributions that could damage the Company's reputation, including, but not limited to, secret payments and benefits.
3.5. Gifts and Hospitality Expenses
Gifts, hospitality and travel expenses may be provided or accepted when welcoming those with whom we do business, to express our appreciation and build strong relationships. They can also be perceived as conflicts of interest or bribery. Gifts may be accepted or given as long as their monetary value and significance do not compromise our objectivity or create a sense of expectation between the two parties.
Our Principles
We will only allow gifts, hospitality and travel expenses if they are in line with accepted business practices, are not excessive in value, are not perceived as an inducement or incentive, and the Company's or employee's reputation will not be harmed by public disclosure of the information.
We will not accept or pay for gifts if the amount of gifts given or received in a calendar year exceeds the value defined in the Gifts and Hospitality Procedure. In the regions where accepting or paying for gifts and hospitality expenses is part of the local culture, we may accept or pay for these expenses only if they are approved in advance by our Company and do not violate laws and regulations.
To avoid conflicts of interest, we report gifts and hospitality provided by any third party to the Board within 3 days.
We do not authorize the provision (or receipt) of gifts to a competitor or to any person or firm doing (or potentially doing) business with our Company.
We do not give anything of value to government officials, including gifts, hospitality and accommodation.
We expect our Business Partners to comply with our gift and hospitality principles. (Guide to Gifts, Hospitality, Accommodation and Travel Expenses).
3.6. Conflict of Interest
A conflict of interest is a situation in which the personal interests of our employees adversely affect or may adversely affect their integrity and impartiality in fulfilling their responsibilities to our Company. Personal interests may include any advantage for employees, their relatives and personal acquaintances.
Our Principles
We avoid situations where personal, financial, social or political activities conflict or appear to conflict with our impartiality.
We (and our relatives and personal acquaintances) will be held responsible for any unfair financial gain and the creation of assets from privileged information received from or about employees.
We may not conduct business on behalf of our Company with our relatives unless authorized in advance by the Ethics Committee.
We disclose our financial interest (or our intention to acquire or sell an interest) in any company or organization to the Ethics Coordinator to identify potential conflicts of interest.
During tender preparations, project teams declare that there is no conflict of interest with any company or individual involved in the tender process..
We sign a Conflict of Interest Commitment during the recruitment process and every subsequent year during our employment.
We strictly comply with regional and international Anti-Monopoly and Fair Competition policies and laws.
We ensure that any Anti-Monopoly and Unfair Competition cases reported to the Legal Department by the Ethics Committee are also reported to the relevant authorities by the Legal Department.
3.7. Evaluating Third Parties
Our relationships with third parties are a very important part of our day-to-day operations. Third parties include subcontractors, consultants, competitors, suppliers, joint ventures, investors and agents with whom we currently interact or may interact in the future. Our due diligence controls cover the company's reputation, financial data, prior business, ownership structure, government relations and operating model.
Our Principles
We work with parties that comply with our ethical values and policies.
We hold third parties accountable to the same integrity standards we apply to ourselves.
We do not knowingly work with a third party that poses a threat to our Company's reputation.
We only work with third parties that are financially capable and independent to complete the agreed work.
We graciously welcome companies that wish to apply their own due diligence processes to our Company.
Our employees may never become an individual supplier of our Company during their employment.
Our Company avoids selecting employees for tender preparations that could potentially cause an Anti-Monopoly situation and create unfair competition issues.
3.8. Privacy and Data Security
Confidential information includes, but is not limited to, our know-how, trade secrets, tender information, customer information, financial data, procurement information and information specified as critical in our "Information and Data Security Confirmation" and applicable laws and regulations. Confidential information is not available to the general public and may not be disclosed outside our Company without proper authorization.
Data protection is the act of protecting our integrity when handling personal data, know-how and other critical data that are part of our Company's assets. Personal data includes, but is not limited to, home addresses, telephone numbers, National ID numbers, photographs, date of birth and any other data that is considered personal data in accordance with applicable laws and regulations.
Our Principles
The confidential information and data we store in our company must always be kept confidential and archived securely in accordance with our "Information and Data Security Confirmation" and relevant laws and regulations.
We are responsible for being informed about our Company's confidentiality and data protection principles and for securely protecting the confidential information of our employees and third parties.
We may not share our Company's and third parties' confidential information with any unauthorized person, including, without limitation, other employees of our Company, relatives and personal acquaintances.
We must be careful when discussing confidential business information and third-party matters in public places where our conversations may be overheard.
We do not ask our employees to share privileged information from previous employment or any other information that could create a risk of an antitrust or unfair competition violation. Similarly, we are mindful of confidentiality obligations even when a person's employment with us ends.
If we have any concerns about how to establish, maintain and protect our company's confidentiality, we seek guidance from our Board and Legal Department.
3.9. Insider Trading
Our employees may obtain or encounter non-public information about our Company and third parties, such as potential acquisitions, financial results, potentially significant business deals, budgets, technical issues and future plans. Such information is "inside information" and may be exploited for the financial gain or benefit of another person or competitors
Our Principles
We never disclose any material non-public information outside our Company. We also do not share information within the Company without authorization.
We do not disclose key nonpublic information to anyone, including any relative or personal acquaintance, even after our employment ends.
We do not purchase another company's securities (such as stocks, bonds, derivatives or other financial instruments) if the price of those securities would be affected by our Company's business decisions. We never engage in insider trading.
We must be aware of applicable laws and regulations regarding the definition of inside information and rules against insider trading.
If we are unsure whether information is publicly available, we consult the Board and our Legal Department for guidance.
3.10. Diversity and Equal Opportunity
Diversity is everything that makes our employees unique as individuals, including, but not limited to, age, gender, race, color, marital status, religion, nationality, political beliefs, economic/class status, disability and sexual orientation. We believe that diversity enriches our Company in providing different viewpoints, fostering innovation and providing the best possible services and solutions for our customers.
Our Principles
Our company advocates the protection of human rights.
We encourage diversity in the work environment.
We provide equal opportunities to all our employees and do not tolerate any form of discrimination, disrespectful or offensive behavior based on age, gender, race, color, marital status, religion, nationality, disability or sexual orientation.
Discriminatory, disrespectful or offensive behavior towards or by our employees will result in disciplinary action.
We do not tolerate harassment of any kind, such as offensive jokes or comments targeted at age, gender, race, color, marital status, religion, nationality, political beliefs, economic/class status, disability or sexual orientation.
We expect our Business Partners to be equally sensitive to our approach to human rights and discrimination. Business Partners will be held accountable for any such behavior or violations.
3.11. Fair Working Conditions
We believe that every employee must have a safe, healthy and respectful working environment to perform at their best. We provide a healthy work environment for our employees and employees of our business partners during their time at our Company. We advocate fair working conditions for all our employees and comply with applicable employment laws and regulations.
Our Principles
We advocate for fair working conditions for our employees and business partners on every project and at all times.
We comply with regional and local laws and regulations regarding working conditions, including working hours, wages and other working conditions. We expect third parties we work with to follow the same principle.
Our company and our stakeholders ensure that employees respect fair working conditions and work in ways that do not jeopardize the health and safety of themselves or others.
We do not tolerate any form of child labor or illegal, abusive or forced labor.
We report any instances of unfair working conditions to our Board and Legal Department.
3.12. Health, Safety and Environment
Health and safety in the workplace includes taking precautions against workplace accidents and promoting a positive working environment for our employees.
We must take the utmost care to be environmentally friendly, demonstrate our care for the environment in every project and always seek innovative long-term solutions.
Our Principles
We strictly maintain a healthy and safe workplace in line with our Quality and Health, Safety and Environment Policy and applicable laws and regulations.
We care about the health and safety of communities near our project sites.
Our employees are personally responsible for reporting workplace accidents and any unsafe or unhealthy working conditions to the Ethics Coordinator and relevant Superiors.
We do not tolerate any use, possession or transfer of illegal drugs, weapons or similar illegitimate materials or substances.
We do not tolerate any form of child labor or illegal, abusive or forced labor.
Our employees are provided with workplace safety training during the recruitment process. Periodic trainings on workplace safety are provided.
We ensure that our business partners are trained and selected in accordance with our quality standards set out in our Quality and Health, Safety and Environment Policy. Our business partners must comply with these standards.
Our business partners must comply with these standards.
We develop and use environmentally friendly technologies that promote the efficient use of natural resources and work in a way that generates minimum waste.
3.13. Legal Responsibility
Legal responsibility is to work in accordance with laws and regulations.
Our Principles
We are committed to carefully comply with the laws and regulations applicable in the regions where we operate and do business.
We periodically check for changes in laws and regulations, both in the countries where we operate and globally.
We are responsible for checking the relevant laws and regulations at all times during the completion of a job or project.
We accept all consequences of violations of laws and regulations.
Our employees should consult the Legal Department when they encounter situations with legal risks. We allocate time and effort for legal counseling to our employees.
We ensure that our employees comply with Ethical principles and policies within the framework of applicable laws and regulations.
4. NOTIFICATION PRACTICES
In case of ethical violations or suspicions, we may report to the Ethics Committee. If your feel uncomfortable, you can send an email to the other option, etik@ccngroup.com (this allows you to remain anonymous).
Any employee who observes a violation or has a concern may report it without hesitation. The CCN Holding Ethics Committee will seriously consider all reports and reports. Employees who report a violation will be protected against any adverse treatment. Retaliation of any kind against employees who report a violation in good faith will not be tolerated. Retaliation is also a type of violation and, if proven, will result in disciplinary action.
If a violation is reported and appropriate action is not taken, the case may be brought directly to the Ethics Committee or the Board of Directors. No employee has the right to retaliate against any report and such action will also be considered a potential violation.
Our Ethics Committee will investigate the reports and take the necessary steps.
4.1 Decision Making (Guidance) Regarding Reporting or Reporting
4.2. Investigating a Violation
Notifications made in accordance with the Ethics Committee Procedure are investigated and necessary action is taken. If a violation is proven, the matter is discussed and a decision is taken by the Disciplinary Committee in coordination with the Ethics Committee. The decision may involve disciplinary action, termination of employment or legal action. Without limitation, the following are considered as violations of the Ethical Principles and Policies:
Violation of Ethical Principles and Policies
Failure to report an observed violation of Ethical Principles and Policies
Retaliation against an employee for reporting a violation
Receiving a report of a violation, but trying to silence the employee who first reported the violation
Any violation investigation handled by the Disciplinary Board is overseen by the Board of Directors
4.3. Ethics and Compliance Training
To maintain awareness of our Ethical Principle, Policies and Procedures, every employee must complete annual Ethics and Compliance training. Such training will provide updates on our Ethical Principle, Policies and Procedures and practical guidance on how to put them into practice.
Ethics and Compliance Training should be completed during orientation and repeated annually.
Any incidents of non-compliance with training requirements will be monitored by the Board of Directors.
4.4. Effectiveness and Review of our Ethical Principles and Policy
The Board of Directors is responsible for ensuring that our Ethical Principles and Policies are up-to-date and reflect changes in our business environment and the way we conduct our business. The effectiveness of our Ethical Principles and Policies will be reviewed by the Board of Directors on an annual basis and any necessary revisions will be identified and approved. Current employees and new hires confirm on an annual basis that they have fully read, understand and comply with our Ethical Principles and Policies.
For more information on our Company policies and procedures regarding the issues addressed in our Ethical Principles and Policies, please refer to the Ethics Committee Working Procedure.
Contact Us for Questions and Concerns
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etik@ccngroup.com
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