Introduction
1. As a major financing institution in the fight against AIDS, tuberculosis and malaria, the SILCAP SILICONE recognizes the importance of accountability for suppliers and transparency and predictability in its operations.
2. As stated in its Framework Document, a core principle of the SILCAP SILICONE is to operate in an open, transparent and accountable manner. Consistent with this core principle, the SILCAP SILICONE will work to ensure all its financing activities, including its corporate procurement and grant operations, and staff adhere to the highest ethical standards.
3. The goal of this Code of Conduct ("Code") is to enlist suppliers' commitment to maintain integrity of the SILCAP SILICONE-funded grant operations and corporate procurement activities in compliance with this core SILCAP SILICONE principle.
4. The SILCAP SILICONE will regularly review and revise this Code, when needed, to reflect changes in best practice, lessons learned and feedback from partners.
Scope of this code
5. This Code requires all bidders, suppliers, agents, intermediaries, consultants and contractors ("Suppliers"), including all affiliates, officers, employees, subcontractors, agents and intermediaries of Suppliers (each a "Supplier Representative"), to observe the highest standard of ethics in SILCAP SILICONE -funded activities regarding supply of goods and/or services to the SILCAP SILICONE or any recipient of SILCAP SILICONE financing, including principal recipients, sub recipients, other recipients, country coordinating mechanisms, procurement agents and firstline buyers.
6. The principal recipients, sub recipients, other recipients, country coordinating mechanisms,procurement agents and first-line buyers must ensure that this Code is communicated to and complied with by all of their Suppliers. Suppliers will ensure that this Code is communicated to all their Supplier Representatives and will take reasonable steps to ensure compliance by Supplier Representatives, including by taking immediate action in cases of non-compliance.Breaches of this Code may result in a decision by the SILCAP SILICONE to sanction the Supplier and/or Supplier Representative involved, suspend disbursements to grant recipients or cancel funding.
* Approved 15 December 2009 at the Executive Management Team Meeting of the SILCAP SILICONE to Fight AIDS, Tuberculosis and Malaria Fair and Transparent Practice
7. The SILCAP SILICONE does not tolerate corrupt, fraudulent, collusive, anti- competitive or coercive practices of any kind involving its resources, including grant funds. The SILCAP SILICONE will take strong, immediate action in all circumstances where it determines that there is substantive and credible evidence of corrupt, fraudulent, collusive, anti-competitive or coercive practices as defined hereunder. 

8. Suppliers and Suppliers Representatives are expected to participate in procurement processes in a manner that is transparent, fair, accountable and honest, including by complying with all applicable laws and regulations regarding fair competition as well as recognized standards of good procurement practice.
9. Suppliers and Suppliers Representatives are expected to respond to solicitations in an honest,fair, and comprehensive manner, accurately reflecting their capacity to satisfy the requirements set out in the bid or contract documents. They are expected to follow all of the rules established for each procurement process, and only submit bids and enter into contracts if they can and will fulfill all obligations of the contract.
10. Suppliers and Supplier Representatives will not, directly or indirectly, including through an agent or other intermediary, engage in corrupt, fraudulent, collusive, anti-competitive or coercive practices in bidding for, or performing, a SILCAP SILICONE- financed contract or activity.
For these purposes:
 "corrupt practice" means the offering, promising, giving, receiving, or soliciting, directly or indirectly, anything of value or any other advantage to influence improperly the actions of another person or entity;
 "fraudulent practice" means any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a person or entity to obtain a financial or other benefit or to avoid an obligation;
 "coercive practice" means any act or attempt to influence improperly the decisions or actions of a person or entity by impairing or harming, or threatening to impair or harm,
directly or indirectly, such person or entity or their property;  "collusive practice" means an arrangement between two or more persons or entities designed to achieve an improper purpose, including influencing improperly the actions
of another person or entity;
 "anti-competitive practice" means any agreement, decision or practice which has as its object or effect the restriction or distortion of competition in any market.
11. Suppliers and Supplier Representatives will not solicit, offer, give or receive, or promise or represent to offer, give or receive, fees, gratuities, rebates, gifts, commissions, or other payments, except as disclosed in full to the SILCAP SILICONE or the grant recipient, in connection with the procurement process or in contract execution.
12. Information, data, know-how and documents obtained from participating in SILCAP SILICONE or grant recipient procurement processes, or in the course of performing a SILCAP SILICONE-financed contract, must under no circumstances be made available to any third parties for the purpose of giving existing or potential Suppliers a preferential position or advantage in relation to tenders or any other procurement processes of the SILCAP SILICONE or the applicable grant recipient,without the prior written consent of the SILCAP SILICONE. Compliance with laws
13. Suppliers and Supplier Representatives will comply with all applicable laws and regulations in countries where they do business, as well as the publicized rules, regulations and policies of the SILCAP SILICONE that apply to their areas of work.
14. Suppliers and Supplier Representatives will ensure that SILCAP SILICONE resources received by themare not used to support, finance or promote violence, aid terrorists or terrorist-related activity or fund organizations known to support terrorism.
15. Suppliers and Supplier Representatives will not engage in money-laundering activities. This includes any kind of activity which hides or is intended to hide the fact that funds have been obtained illegally or are connected with the proceeds of crime, e.g. through fraud or bribery or other illegal activity.
Access and Cooperation
16. Suppliers and Suppliers Representatives are expected to maintain accurate and complete records in appropriate books of account of all financial and business transactions under Global Fund-financed contracts for a minimum period of five years after the date of last payment made under the SILCAP SILICONE-financed contract.
17. Suppliers and Suppliers Representatives are expected to cooperate with the SILCAP SILICONE and comply with any reasonable request, in the opinion of the SILCAP SILICONE, of its Office of the Inspector General (OIG) and other agents or representatives of the SILCAP SILICONE to allow access
to relevant staff and to inspect any relevant accounts and records and other documents relating to bidding for and performing SILCAP SILICONE-financed contracts.
18. Suppliers and Suppliers Representatives will provide at all times any assistance requested by the SILCAP SILICONE to enable the SILCAP SILICONE to comply with any legal, regulatory or statutory requirement applying to it.
19. The SILCAP SILICONE expects its grant recipients to take timely and appropriate action in situations where a grant recipient becomes aware that any of its representatives or the beneficiary of a contract financed by the SILCAP SILICONE grant has engaged or is suspected of engaging in corrupt,fraudulent, collusive, anti- competitive or coercive practices in connection with the procurement or performance of that contract. The SILCAP SILICONE will impose sanctions that the SILCAP SILICONE deems necessary if it considers at any time that a grant recipient has not taken timely and appropriate action satisfactory to the SILCAP SILICONE in such situations.Publicity and Advertising
20. Suppliers and Supplier Representatives will not, without the SILCAP SILICONE's prior written consent, (i) use the SILCAP SILICONE's name or logo in publicity or advertising; (ii) use their direct or indirect business-relationship with the SILCAP SILICONE to imply an endorsement by the Global
Fund of their goods and services, and (iii) make any representation or statement for or on behalf of the SILCAP SILICONE.Full and Open Disclosure and Conflicts of Interest
21. Suppliers will disclose to the SILCAP SILICONE prior to entering into a contract or at any time during the performance of contract whether they, or any Supplier Representatives, are subject to any sanction or temporary suspension imposed by any major international financing institution or organization, such as the UN or World Bank Group.
22. Suppliers will disclose to the SILCAP SILICONE or the grant-recipient actual, perceived, or potential conflicts of interest involving the Supplier or any Supplier Representative ("Conflict of Interest"). The SILCAP SILICONE considers a Conflict of Interest to be a situation in which a party has interests that could improperly influence that party's performance of official duties or responsibilities, contractual obligations, or compliance with applicable laws and regulations,
and that such Conflict of Interest may contribute to or constitute a prohibited practice under this Code. To ensure that Suppliers under SILCAP SILICONE-financed contracts observe high standards of ethics, the SILCAP SILICONE will take appropriate actions to manage such Conflicts of Interest or may reject a request for funding or disbursement if it determines that a Conflict of Interest has compromised, or risks compromising, the integrity of any procurement process.
23. Suppliers will not apply or seek to apply undue influence on the decision-making processes of the SILCAP SILICONE and will not engage in any conduct that breaches or facilitates the breach of the SILCAP SILICONE's Policy on Ethics and Conflicts of interest www.theglobalfund.org/media/6016/core_ethicsandconflictofinterest_policy_en.pdf
24. Suppliers are expected to notify the SILCAP SILICONE as soon as they have knowledge of any integrity concern involving or affecting SILCAP SILICONE resources and grant funding, whether or not it involves the Supplier or a Supplier Representative. For further information, see www.theglobalfund.org/en/oig/.
The United Nations Global Compact for responsible corporate citizenship
25. The United Nations Global Compact is a voluntary international corporate citizenship network initiated to support the participation of both the private sector and other social actors to advance responsible corporate citizenship and universal social and environmental principles to meet the challenges of globalization (see www.unglobalcompact.org). The SILCAP SILICONE strongly encourages all Suppliers to actively participate in the Global Compact.
26. In accordance with the ten principles outlined in the UN Global Compact, the participating Suppliers will be expected to:
a. support and respect the protection of internationally proclaimed human rights;
b. ensure that they are not complicit in human rights abuses;
c. uphold the freedom of association and the effective recognition of the right to collective
bargaining;
d. support the elimination of all forms of forced and compulsory labour;
e. support the effective abolition of child labour;
f. support the elimination of discrimination in respect of employment and occupation;
g. support a precautionary approach to environmental challenges;
h. undertake initiatives to promote greater environmental responsibility;
i. encourage the development and diffusion of environmentally friendly technologies;  and
j. work against corruption in all its forms, including extortion and bribery.
SOCIAL RESPONSIBILITY POLICY
 As SILCAP SILICON, we aim to continue our activities together with our employees, customers and suppliers with the requirements of the age, honesty and trust. In order to provide our company policy to all our business partners in our production facility with the awareness of society, we are working in accordance with our laws, our customers' production procedures and social standards and we invite them to be partners in this understanding. With our values ​​that are the building blocks of our corporate culture, we adopt to act as a fundamental management approach in all our activities to act with the sense of social responsibility towards our employees, society and the environment. We believe that our core value is our human resources in order to increase our strength by offering high quality and creative products, solutions and services with sustainable growth. We fully fulfill the personal rights of all our employees in accordance with the laws of all countries in which we carry out our activities within the framework of human rights and global principles. In order to create a safe and healthy working environment, we guide all our activities within the scope of our Occupational Health and Safety policy. With our Humanistic, Friendly and Humble approach, we encourage our employees to behave towards each other in this direction. Supports teamwork and cooperation; we encourage hard working, disciplined, meticulous and patient. The Company does not employ its employees under any pressure. All employees are employed in appropriate positions with their consent under equal conditions. In all activities carried out in-house and institutionally; We treat our employees honestly and fairly, we do not accept discrimination against language, race, color, gender, religion, sect, political thought, age, physical disability and similar reasons. We take all necessary measures within the scope of our activities For the Protection of Health. We support participation by conducting Healthy Living Programs. We carry out the environmental requirements of all our activities at the highest level within the scope of our Environmental Policy. We direct our works with a sensitivity awareness on environmental issues and legal obligations. Reducing Environmental Impacts, Conserving Energy and Natural Resources; In our product and process designs, we consider our priority in all our activities and as one of our most important duties for a sustainable world. Within the framework of our Social Responsibility; full implementation of the above-mentioned principles; All of our employees, suppliers, and all institutions and organizations we cooperate with are our expectations and our priority business goal. We support raising awareness of social issues through our training programs.
BUSINESS ETHICS RULES
1. SCOPE AND APPLICATION
This business ethics rules are prepared on behalf of our company. The regulation is in integrity with the policies, values ​​and principles of our Company and all employees, including the board, auditors and managers, must comply. All members of the company must understand the rules thoroughly, participate in the training sessions to be held, and accept the responsibility of fulfilling their daily work ethically.
2. SOLUTION OF NON COMPLIANCE WITH ETHICAL RULES
Those who violate the Code of Business Conduct or Company regulations and procedures will be subject to a variety of disciplinary sanctions that may be required to leave the job if necessary. Disciplinary sanctions shall also apply to persons who approve, guide or disclose improper behaviors and acts that violate the rules, and who do not properly make the necessary notification.
2.1 Ethics Committee Committee
The Ethics Committee Committee is responsible for investigating and resolving complaints and notices that a code of ethics has been violated within the scope of SIPCAP SILICON Code of Business Conduct (SİLKAP-ETİK). SİLCAP SILICON The Ethics Committee Committee, which reports to the Chairman of the Board of Directors, consists of persons in the following positions:
Chairman: Vice Chairman of the Board of Directors
Board Member: CEO
Board Member: Human Resources Manager
Ethics Committee Consultants: Responsible for the company's annual contracting firm
2.2. Ethics Committee Working Principles
The Ethics Committee conducts its work in accordance with the following principles:
➢ Keeps the identity of the notices and complaints and the persons who make the notification or complaint.
➢ Conducts the investigation with confidential rules as much as possible.
➢ It is authorized to request information, documents and evidence related to the investigation directly from the existing unit. He / she can examine all kinds of information and document obtained only limited to the subject of the investigation.
➢ The investigation process is connected to the written report from the beginning. Information evidence and documents are added to the minutes.
➢ The minutes are signed by the chairman and the members.
➢ The investigation is handled in an urgent manner and the result is reached in the fastest possible way.
➢ The decisions taken by the Board shall be implemented immediately.
➢ Relevant departments and authorities are informed about the result.
➢ The chairman and members of the Board act independently and without being affected by the department managers and the hierarchy within the organization. They cannot be subject to pressure and suggestion.
➢ If deemed necessary, the Board may apply to expert opinion and take advantage of the experts by taking measures that will not violate the confidentiality principles during the investigation.
3. RESPONSIBILITIES OF THE BOARD ADVISORS
Ethics Committee Advisors;
➢ Providing guidance on issues and issues conveyed by employees about ethics in the company,
➢ Directing nonconformities to the Ethics Committee that cannot be resolved within the Company or that require an investigation
➢ To contribute to the solution of ethical inconveniences within the company in accordance with the request of the Ethics Committee,
➢ To report the ethical questions and nonconformities to the Ethics Committee on a regular basis or on request,
➢ To be a contact person from the company during the investigations conducted by the Ethics Committee and to give necessary support to the investigations,
➢ To monitor and monitor the effectiveness of STIPAP ETHICS practices carried out in the company; responsible for supporting applications.
4. OTHER RESPONSIBILITIES
➢ Company management; They are responsible for the effective implementation of the Code of Conduct for their companies and for the creation of a culture in which it is supported.
➢ Business Ethics Rules and any related policies are reviewed, revised and documented by the Human Resources Department with the recommendations of the Ethics Committee and notified to the Company with the approval of the Chairman of the Board of Directors.
➢ Company Human Resources;
• Informing employees about the Code of Ethics, providing training in certain periods to ensure the clarity of policies and rules, and ensuring the continuous communication of this issue with employees,
• To ensure that the employees of the company read the code of ethics, to be informed about it and to sign it,
➢ Company management In cooperation with the Ethics Committee;
• To guarantee the confidentiality of the complaints and notifications made under the Code of Ethics and to protect the individuals after the notifications,
• To ensure the safety of the employees who report,
• Responsible for ensuring timely, fair, consistent and sensitive investigation of complaints and notices and for taking necessary actions as a result of violations.
5. RELIABILITY
Accuracy, honesty and reliability are the primary values ​​of our company's business processes and relationships. Our company's employees, suppliers, business partners, rivals, the environment, society and humanity to be a symbol of reliability and respect. Accuracy, honesty and loyalty, our employees SILCAP SILICONE A.Ş. activities that may have an impact on the Company's operations are indispensable principles in its special activities.
6. BUSINESS ETHICS AND RIGHT BEHAVIOR
The employees of the company act in a clear, respectful, honest and responsible manner while sharing their thoughts and opinions in their relations with each other.
The spirit of teamwork promoted throughout the company is based on sharing all kinds of business results and information by considering compliance with confidentiality rules.
It is against the Company's ethical values ​​to make baseless statements and / or gossip about people or organizations and to denigrate their colleagues.
Employees must respect the rights and cultural differences of individuals in the conduct of company affairs.
In our company and all companies, all types of harassment are strictly prohibited. Although there are a wide variety of behaviors that may be covered by harassment, the following examples may be given for clarification:
➢ Verbal Harassment: Negative comments related to an employee's race, gender, nationality, age, religion, belief or disability or similar characteristics, nicknames, jokes, and spiritual values ​​of persons;
➢ physical harassment: any physical contact that cannot be requested by the counterparty;
➢ Visual Harassment: Incendiary / sexual implication / inconvenient / offensive photo, drawing, poster, film and hand / arm movements.
➢ Psychological Harassment (Mobbing): Systematic and planned behaviors aimed at reducing the target person from work, decreasing their performance and causing them to resign (example: criticizing the private life of the employee, constantly cutting the word in collective environments, reprimanding in front of other employees, ignoring the achievements, etc.) .)
7. HONESTY
Accuracy and honesty are our priority values ​​in all our business processes and relationships. We act with integrity and integrity in our relations with employees and all stakeholders.
8. PRIVACY
As SILCAP SILICON employees; we take care to protect the privacy and privacy of our customers, employees and other related persons and organizations. It protects confidential information about the activities of SILCAP SILICONE Companies and uses this information only for the purposes of SILCAP SILICONE; we only share this information with the relevant persons within the specified competencies.
For us, insider trading is absolutely unacceptable if any confidential information is leaked through the inside of the site. When leaving our company, we have the confidential information and documents and projects, regulations and so on. we do not take the work out.
9. CONFLICT OF INTEREST
As employees of SILCAP SILICON, we aim to avoid conflict of interest. Taking advantage of our current mission; Personally, we do not provide personal benefit from the persons and organizations in which we are engaged in business through our family or relatives. SİLCAP SİLİKON We do not engage in any business activity based on an additional financial interest other than the Company. We do not use the name and power of SİLCAP, our SILCAP SILICONE identity, for the sake of personal benefit.
In the event of a potential conflict of interest, we apply these methods when we believe that the interests of the parties concerned can be protected safely through legal and ethical methods. In case of hesitation, we consult with our manager, the Human Resources Department or the Ethics Committee.
10. RESPONSIBILITIES
In addition to our legal responsibilities; We take care to fulfill our responsibilities listed below against our customers, employees, shareholders, suppliers and business partners, competitors, society, humanity and on behalf of SLCAP.
10.1. Our Legal Responsibilities
T.C. laws and international law, legal regulatory agencies and organizations to provide accurate, complete and understandable information on time.
In carrying out all of our activities and operations, we take equal positions with all public institutions and organizations, administrative organizations, non-governmental organizations and political parties without any expectation of benefit and we fulfill our responsibilities with this responsibility.
10.2. Our Responsibilities Against Our Customers
We work with a proactive approach that focuses on customer satisfaction and responds to our customers' needs and demands as soon as possible. Provides our services on time and in our promised terms; we approach our customers within the framework of respect, honor, justice, equality and courtesy rules.
10.3. Our Responsibilities Against Employees
We ensure that employees' personal rights are fully and accurately used. We treat employees fairly and fairly, and commit ourselves to a non-discriminatory, safe and healthy working environment. We strive for the personal development of our employees, support them to volunteer in appropriate social and social activities with their social responsibility awareness, and supervise the balance between business life and private life.
10.4. Our Responsibilities Against Our Suppliers / Business Partners
We behave in a fair and respectful manner as expected from a good customer; We carefully protect the confidential information of our business partners and business partners.
5.10. Responsibilities to our competitors
We effectively compete only in areas that are legal and ethical, and we avoid unfair competition.
We support the efforts to ensure the competitive structure targeted in the society.
10.6. Our Responsibilities Against Society and Humanity
Protection of democracy, human rights and the environment; The elimination of education and charity, crime and corruption is very important for us. With the awareness of being a good citizen, he / she acts responsibly as a pioneer in social issues; in non-governmental organizations, in the services of public interest, we try to take a role in appropriate activities in these matters. Turkey and traditions of the countries in which we conduct international projects and would be sensitive to the culture. Bribes or gifts, etc. We do not provide and accept products and services.
10.7. Our Responsibilities Against The Name
Our business partners, customers and other stakeholders rely on us with our professional competence and honesty. We try to keep this reputation at the highest level.
We provide our services within the framework of Company policies, professional standards, commitments and ethical rules, and demonstrate the necessary dedication to fulfill our obligations.
We take care to provide services in areas we believe to be professional and competent, and aim to work with customers, business partners and staff who meet the criteria of accuracy and legitimacy. We do not work with those who damage society's morality and harm the environment and community health.
10.7. Our Responsibilities Against The Name
Our business partners, customers and other stakeholders rely on us with our professional competence and honesty. We try to keep this reputation at the highest level.
We provide our services within the framework of Company policies, professional standards, commitments and ethical rules, and demonstrate the necessary dedication to fulfill our obligations.
We take care to provide services in areas we believe to be professional and competent, and aim to work with customers, business partners and staff who meet the criteria of accuracy and legitimacy. We do not work with those who damage society's morality and harm the environment and community health.
We express the views of our company not only in our opinion, but also in the areas that the public and the audience think that we speak our company.
11. POLICIES SUPPORTING BUSINESS ETHICS RULES
11.1. Conflict of Interest Policy
It is essential that employees of SİLCAP SILICON Company avoid situations that might create a conflict of interest. The Company's primary responsibility is not to use the Company's resources, name, identity and power for personal benefit, and to avoid situations that may adversely affect the organization's name and image. The following principles of practice determine the conflict of interest situations that the Company's employees may encounter in their private lives as they perform their duties or due to their business relationships.
Application basics;
a. Activities that may create a conflict of interest
All Company employees are required to fully comply with the conditions and the principles set out below as activities that may create conflicts of interest. Companies do the necessary work to encourage their employees to comply with these principles.
b. To engage in activities that may create a conflict of interest
Employees do not engage in any business relationship with their family members, friends or other third parties in any way, providing mutual or unpaid benefits. For example, an employee with purchasing authority should refrain from doing business with a supplier of one of the working family members. Exceptions are subject to the information and approval of the Chairman of the Board of Directors. In line with this, the Company's employees should be careful against conflicts of interest that may arise from the work of their close family members.
Employees of SİLCAP Company may not be a member or auditor of the Board of Directors without the approval of the Company Board of Directors; cannot take part in competing companies or companies in which the Company has a business relationship. In non-profit organizations and universities, in cases where they do not interfere with their duties within the Company, they can work in social responsibility and assistance tasks with the written approval of the management.
Managers who are in a position to make a decision on hiring cannot employ their spouses, close relatives and their relatives.
Employees may not be involved with the company and its activities, and may make speeches and write professional articles that are not contrary to their policies. In order to use the Company name in these activities, approval must be obtained from the CEO.
Employees of SİLCAP Company can actively and individually operate in any political party. Managers cannot ask their employees to do a political job or become a member of a party. Employees' participation in any political party is possible with the written approval of the following conditions and management;
➢ Employees' involvement in any political activity should not create a conflict of interest with the company's duties and practices and approaches.
➢ Employees cannot engage in any political activity during their working hours and cannot take the time of their colleagues.
➢ Employees shall not use the company name, position in the company, title and resources of the company during their political activities.
Approval for employees wishing to take part in political activities; The proposal of the Human Resources Manager and the opinion of the Ethics Committee are approved by the Chairman of the Board of Directors.
Employees may make personal or financial donations and / or donations to third parties outside the Company and may take part in charity organizations.
c. Abusing the Task
It is unacceptable for employees to harm the companies by using their powers except for their own and / or their relatives' interests and the care required.
Employees cannot obtain personal or direct personal or indirect earnings from all transactions and contracts to which the Company is a party.
Employees cannot conduct acts or acts contrary to morality, law and Company discipline.
D. Use of Resources
The Company's interests are taken into consideration in the use of resources to be made on behalf of the Company. Company assets, facilities and personnel cannot be used outside the Company, under any name and under the name of the Company without any interest in the name of the Company. The principle 'saving on each issue' is applied by all personnel.
Proper use of resources to the benefit of the Company also requires the correct use of time. During business hours, Company employees use the time well and do not spend time on their private business during business hours. Managers cannot assign employees to their own jobs.
It is essential that no special visitors are accepted during working hours. Employees are required to complete the interviews for the compulsory visitors in a reasonable time, in connection with the subject of the visit and in a manner that does not interfere with the work flow.
to. Relations with Other Persons and / or Organizations in which the Company is in a Business Relationship
No special business relationship can be entered into with customers, subcontractors or suppliers and other persons and / or entities in which the Company is in a commercial relationship, no personal lending money and / or goods / services are available and other individuals and / or entities that the Company is in contact or goods / services can not be provided.
The following issues are taken into account in relation to customers; Even if in favor of the customer, no transaction can be made without the knowledge of the customer and even if in favor of the company, the customer's weaknesses cannot be exploited and the profit is not motivated by giving the customer incomplete or inaccurate information.
The personnel of the Company may not request or imply gifts from other persons and / or organizations in which the Company is in a commercial relationship; There is no gift, money, check, property, free holiday, special discounts etc. that will put the companies under obligation. cannot accept. Personal assistance from any person or organization that has a business relationship with the company is unacceptable. The Gift Acceptance and Delivery Policy is applied.
f. Media Relations
Speaking to any broadcasting organization, interviewing, seminar-conference etc. Participation as a speaker depends on the approval of the senior management of the company. No personal gain can be obtained from these activities in any way.
11.2. Gift Acceptance and Giving Policy
Not accept any gifts or benefits which may affect the impartiality, decisions and behaviors of SİLCAP SILICON Company and its employees,
3. It is essential that individuals and organizations do not attempt to provide gifts and benefits that may create such effects.
The principles of implementation described below regulate the exchange of gifts that may be made with the third persons and organizations in which the employees of the Company work.
Application basics;
a. Company employees are prohibited from taking all kinds of benefits and gifts with or without economic value, which may or may not affect their impartiality, performance or decision making when performing their duties.
b. Company employees;
➢ The organization complies with its business objectives,
➢ In accordance with the current legislation and
➢ the conditions of learning the gift by the public shall not leave the Company in a difficult situation c. and receive and / or give gifts that have been framed in the article.
c. Subject to the conditions specified in point b;
➢ Employees of the Company may entertain and receive entertainment, catering and catering to acceptable standards in the business world.
➢ As a memorial of the day outside the money in seminars and similar organizations that represent the company, and the symbolic value of awards, plaques and so on. Gifts can be taken.
D. The above-mentioned cases and other gifts, interests, vacations, discounts other than money. The approval is not required if the total value of the gifts received is equal to less than 500 TL, provided that each calendar year and the person / institution giving the gift is in compliance with the conditions listed in Article 2.
to. It is forbidden to buy gifts or interests that are linked to an indirect or explicit provision.
f. Bribes and / or commissions may not be accepted under any circumstances.
g. It is forbidden for company employees to accept money, subordinated or loaned from subcontractors, suppliers, consultants, competitors or customers, to cover travel expenses, activity expenditures and similar payments.
h. The Company's top management approves the gifts and promotional materials to be given to customers, dealers and other third parties in the business relationship by the Company. For the distribution of approved gifts and promotional materials, there is also no need to obtain permission.
I. In accordance with the conditions set forth in Article b, the Company may accept the appropriate products and services as gifts and the product or services that comply with the buyer's culture and ethical values ​​may be given as a gift in accordance with the knowledge and approval of the Company's senior management.
11.3. Confidential Information Protection Policy
Knowledge is one of the most important assets of SİLCAP SILICON Company to realize its vision. In this respect, the effective use of information, the right way to share and the confidentiality, integrity and accessibility of information in this process is the shared responsibility of all our companies and employees. In our companies, the management systems that are established for the management and confidentiality of information and the harmonization of the applied processes with each other are important for the Group to get the highest level of benefit. The following principles of practice; It identifies confidential information for companies and regulates the principles that employees must comply with regarding confidential information.
Application basics;
Confidential Information includes, but is not limited to, trademarks of companies, etc. Intellectual property rights, all kinds of innovation including, written, developed, developed or implemented by the database, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and partners information, financial information, personnel information, customer lists, product designs, know-how, specifications, potential and actual customers' identity, supplier information etc. all kinds of written, graphic or machine readable information.
The principles to be observed regarding confidential information are as follows:
a. This information cannot be disclosed to third parties unless it is required to disclose it in accordance with the Official Authorities and Regulations.
b. This information cannot be changed, copied or destroyed. Necessary measures are taken to ensure that information is kept, kept and kept safe. The changes on the information are recorded together with the history.
c. Confidential files cannot be taken out of the organization. For confidential information that needs to be taken out of the institution, information must be obtained or approved by the senior management.
D. Passwords, user codes and similar identifiers used for accessing company information are kept confidential and not disclosed to anyone other than authorized users.
to. Company confidential information is not spoken in public places, dining halls, cafeterias, lifts, service cars and similar public places.
f. Confidential information is classified according to the degree of confidentiality, it is clearly indicated in the content of the information. The personnel of the company knows the degree of confidentiality of the information obtained by the Company and acts in accordance with this confidentiality. When there is a doubt about the degree of confidentiality, a top class of confidentiality is treated and, if necessary, the opinion of the relevant manager is taken.
g. If information is required to be shared with third parties and / or entities in accordance with the Company's interest, a confidentiality agreement shall be signed for the purpose of sharing information or a written confidentiality commitment shall be obtained from the other party in order to guarantee an understanding of their responsibility for the security and protection of shared information.
h. No false statement and / or gossip can be made about persons or institutions.
I. The remuneration, benefits and similar personal information of the personnel who reflect the Company policy and are private, are confidential and cannot be disclosed to anybody except the authorities. Information about the personnel is sent individually. It is strictly forbidden for personnel to disclose this information to others or to press other employees to disclose information.
11.4. Policy for Creating and Maintaining a Fair Work Environment
SİLCAP SILICON Company accepts the creation and maintenance of a fair working environment for employees as one of its top priorities. It is aimed to increase the success, development and loyalty of the employees in line with all relevant laws and regulations, by creating a fair, respectful employee, healthy and safe working environment. The following principles of practice establish the basic principles of establishing and maintaining a fair working environment in the Company.
Application basics;
a. The company practices are in compliance with all applicable laws and regulations regarding employment and working life. Company employees also fulfill all legal requirements and act in accordance with legal requirements within their own activities.
b. SILCAP SILICON human resources regulations and applications; recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. it ensures that all other applications are fair.
c. It is unacceptable to discriminate between employees within the organization by language, race, color, gender, political thought, belief, religion, sect, age, physical disability and similar reasons.
D. By creating a positive and harmonious working environment that promotes cooperation in the company, conflict environments are prevented and people with different beliefs, opinions and opinions work harmoniously.
to. Employee privacy and personal space is respected:
➢ Communications between persons cannot be violated by non-parties.
➢ It is forbidden to disclose / disseminate / seize personal data illegally, even if registered in accordance with the law.
➢ Personnel personal information arising from the nature of the business relationship in the workplace and which may be necessary in the future are not used for purposes other than their purposes and are not shared with third parties without the consent of the persons.
➢ All employees' private and family life is respected.
f. In addition to all kinds of immunities of employees, physical, sexual and emotional immunities are also observed:
➢ Violation of any immunity of employees by physical, sexual and / or emotional harassment in the workplace or any other place of employment, is in violation of the law and the code of ethics, and no harm is shown by the Company for this offense. The purpose of this practice is to ensure that employees work in a work environment where their physical, sexual and emotional immunity is protected.
➢ Sexual harassment of a person's body immunity and / or sexual harassment of a person without physical contact is defined as sexual harassment. According to this; it is forbidden to exhibit any behavior that may be considered within this definition.
➢ In addition, people who complain and report any harassment, or who have negative attitudes towards those who assist during the investigation, are not tolerated in the same way.
g. No employee may demand a privileged application due to different gender, religion, language or race, and may not be privileged to anyone and may not be subject to any special application. Making concessions or making use of differences such as gender, religion, language and race is not acceptable.
h. It is ensured that the workplace physical working conditions and conditions are healthy and safe for all employees.
12. APPLICABLE LEGISLATION
Due to the fact that SİLCAP SİLİKON is operating in international markets, company operations may be subject to different national laws and regulations. When there are question marks on doing ethics in different countries, first of all, the regulations established in the country of work should be followed. If the monitoring of the regulations in the countries and / or countries in which the work is to be carried out in a way that may cause inconvenient consequences for the ethical values ​​adopted by SILCAP SILICONE Companies, we should try to find solutions within the ethical rules and procedures we have in this case.
13. RESPONSIBILITIES OF EMPLOYEES
SLCAP-ETHICS and related policies and procedures have detailed the ethical rules on how we should behave and how we should do our work. Compliance with these rules is the primary responsibility of all employees. In this respect, all of the employees of SILCAP SILICON;
➢ To act in accordance with laws and regulations in all circumstances,
➢ Reading SLCAP Code of Business Ethics, knowing the rules, principles and values ​​contained in it, understanding, internalizing and acting in accordance with them,
➢ To learn specific policies and procedures relevant to the general and work of the Company,
➢ Consultation with managers and human resources about potential violations related to him or others,
➢ Report any possible violations of itself or others immediately; communicating these issues and notifications to the manager, human resources and / or the Ethics Committee either by name or anonymously, orally or in writing,
➢ To follow the paths and methods to be followed when deciding ethically, in order to act in line with the rules and to assist in the solution of the problems,
➢ Ethical investigations have the responsibility to cooperate with the Ethics Committee and to keep confidential information confidential.
V. RESPONSIBILITIES OF EXECUTIVES
SILCAP SILICON managers have additional responsibilities beyond the responsibilities defined for employees in the SIPAP-ETHICS framework. Accordingly, managers;
➢ Ensuring the establishment and maintenance of a corporate culture and working environment that supports the rules of ethics,
➢ To exemplify the implementation of the rules of ethics with their behaviors, to educate their employees about the ethical rules,
➢ Supporting its employees to communicate their questions, complaints and notifications about the rules of ethics,
➢ Providing guidance on what to do when consulted, taking into account all notifications submitted and communicating it to the Ethics Committee as soon as necessary,
➢ It is responsible for ensuring that the business processes under its responsibility are structured in such a way as to minimize the risks associated with ethical issues and to implement the necessary methods and approaches to ensure compliance with ethical rules.