PURPOSE AND SCOPE
Ethical Principles and Code of Conduct refer to a set of behaviors based on the principle of honesty. The Ethical Principles aim to guide all parties involved in business processes to act not only with legal and commercial obligations but also with ethical responsibility. These principles regulate the relationships among customers, employees, business partners, suppliers, and their interactions with public institutions and society.

These Ethical Principles also define the fundamental requirements that Yildizlar Yatirim Holding A.Ş. and Group Companies expect from their suppliers, customers, business partners, and third-party intermediaries regarding their obligations toward stakeholders and the environment. Having accepted this document, the Suppliers, Customers, Contractors, and/or third-party intermediaries also declare the following: 

ETHICAL RULES AND CODE OF CONDUCT

Respect for Fundamental Human Rights and Freedoms
The primary goal is to base all actions on respect for human rights and freedoms, and the same sensitivity must be demonstrated by business partners, customers, and suppliers in all business activities. The use of child labor is unacceptable. No supplier or customer can employ children as labor. No employee can be subjected to forced labor; all employees are valued, and equal opportunities are provided.

Occupational Health and Safety
Ensuring occupational health and safety in workplaces and on the job is mandatory. Employees are required to adhere to the rules and instructions established for this purpose and take the necessary precautions. Employees cannot possess any items or substances at the workplace that pose a danger or are illegal concerning the workplace and/or other employees. Occupational accidents and diseases are prevented by complying with the legal obligations related to occupational health and safety.

Compliance with Law and Rules and Legal Obligations
All activities and operations at home and abroad are carried out in accordance with the laws of the countries in which the company operates and international law. Accurate and timely communication with regulatory and supervisory bodies must be prioritized.

Impartiality, Fairness and Justice
All business relationships must be approached without any discrimination, fairly, and without prejudice. While fulfilling duties and responsibilities, no discrimination should occur based on language, religion, race, gender, ethnicity, political opinion, or other differences.

Confidentiality
Ideas, projects, inventions, works, methods, progress, all written or verbal commercial, financial, technical documents, personal data and conversations, correspondences and all other information, to be acquired in the course of business, all owned by Yildizlar Yatirim Holding and Group Companies are considered confidential information. The obligation to comply with confidentiality, the subject of this article, covers all kinds of interviews, meetings, discussions, and correspondences. Confidential information includes, but is not limited to intellectual property rights and all sorts of innovations owned by Yildizlar Yatirim Holding and Group Companies, as well as databases written, found, developed, or implemented by the personnel, printed communication materials, business processes, advertisements, product packaging, and labels, business plans (marketing, product, technical), business strategies, strategic partnerships and information regarding partners, financial information, personnel personal information, customer lists, prices, product designs, know-how, specifications, identity information of potential and actual customers, information regarding suppliers and all kinds of information whether written, in graphic or machine-readable. Confidential information is fully protected by employees, business partners, suppliers, and customers.

Transparency and Honesty
As Yildizlar Yatirim Holding, we observe the principles of honesty, integrity, and transparency in all processes while carrying out our activities.

Fight against Corruption and Bribery
Any form of corruption or bribery should not be tolerated and should not be directly or indirectly engaged in. Nothing of value should be given, offered, or promised to a government official or private sector counterparty for the purpose of influencing official action or obtaining an unfair advantage.

Environmental Awareness, Respect and Security
While carrying out all activities, it is essential to act with the principles of protecting the environment and respecting the environment, not only for profitability but also for social benefit. Methods for protecting natural resources such as energy and water should be developed and studies should be carried out for the efficient use of energy and materials. Recycling and reuse processes should be implemented to prevent air, water, and soil pollution and to reduce the amount of waste.

Use of Resources
Holding and Group Companies' assets, facilities, and personnel cannot be used outside the Holding and Group Companies, under whatsoever name and in whose name, and for whose benefit, without the benefit of the Holding and Group Companies. The principle of "savings in all matters" shall be applied by everyone.

No time shall be allocated for personal matters during working hours. The managers cannot assign employees to personal affairs. No personal visitors can be accepted during working hours. Employees must complete meetings for essential visitors within a reasonable time frame that is relevant to the subject of the visit and does not disrupt the workflow.

Computer systems, corporate e-mail accounts, and the internet cannot be used inappropriately.

Media
Giving a statement to any media organization, giving an interview, participating as a speaker in a seminar or conference, etc. is subject to the approval of the Yildizlar Yatirim Holding Board of Directors. No personal gain can be obtained from these activities.

Protection of Personal Data
While performing their duties, employees, suppliers, customers, and business partners are obliged to act as per the laws, regulations, and policies issued on the protection of personal data (general data processing, special data processing, storage, and destruction) and the regulations brought about by these, the Law on the Protection of Personal Data and all other relevant legislative provisions.

Compliance with Competition Laws
Agreements that could create a dominant position in the market with competitors, influence pricing and marketing policies, or violate competition regulations shall not be entered into. Compliance with competition laws is an asset.

Third-Party Perspective
In all activities, public institutions and organizations, non-governmental organizations, and political parties should be kept at an equal distance without expecting any benefit. Situations possibly resulting in a conflict of interest in current duties and obligations due to political activities undertaken should be avoided. The Company name, title, and resources cannot be used in individual political activities. Political propaganda cannot be made during working hours and the workplace environment, employees cannot be asked to be members of a political party in any way, and other employees' time cannot be taken up concerning these activities.

Relationships with Suppliers, Customers, and Business Partners
Care must always be taken to be honest and fair in relations with all suppliers, customers, and business partners. Suppliers, customers, and business partners are required to act in compliance with laws and regulations in their activities, protect the rights of their employees, and protect the environment and nature.

It is mandatory for all Suppliers, Customers, and business partners to comply with these Ethical Principles and Working Principles and to act within this framework by sharing the same values.

Acceptance and Rejection of Gifts
Yildizlar Yatirim Holding and Group Companies’ employees and all suppliers, customers, and business partners cannot ask for gifts, benefits, assistance, hospitality, special discounts, commissions, or discounts that may affect their impartiality, decisions, and behaviors for their own benefit, or accept such offers.

Yildizlar Yatirim Holding and Group Companies’ employees are prohibited from accepting free or loaned money from subcontractors, suppliers, consultants, competitors, or customers, or getting travel expenses, event expenses, or similar payments covered. However, Yildizlar Yatirim Holding may, upon the approval of the Board of Directors, engage in activities sponsored or covered by third parties (e.g. SAP forum, factory tours, technical tours, educational tours, free conferences, introductory meetings, organizations open to general participation, sports and similar activities).

Self-Dealing
Employees of Yildizlar Yatirim Holding and Group Companies do not have any financial interest in any organization that is in a relationship with the Group Companies, any suppliers, customers, business partners, competitors, or customers or that they are trying to do business with, nor do their family members or other relatives have any financial interest to their knowledge.

Non-Solicitation
In order for employees who leave Yildizlar Yatirim Holding and Group Companies to work for Yildizlar Yatirim Holding and Group Companies as a vendor, contractor, consultant, broker, representative, dealer, or the like, there must be no conflict of interest due to the positions they held in the Holding or Group Company they previously worked for. Provided that these conditions are met, the approval of the Board of Directors is required for those who leave their jobs to work with Yildizlar Yatirim Holding and Group Companies.

Conflicts of Interest
Yildizlar Yatirim Holding, its Group Companies, and all suppliers, customers, and business partners refrain from engaging in business activities that could create conflicts of interest or are based on additional financial gain in their business-related operations.
In cases of potential conflicts of interest, the interests of the relevant parties are protected by applying legal and ethical methods. In case of any uncertainty, the Ethics Committee is consulted.

Environment and Energy
The protection of the environment and the achievement of a healthy ecological balance are supported, and compliance with related regulations is ensured.  

As a corporation, we adopt and prioritize the preservation of natural resources, maintaining clean air and water, balanced energy use, and waste reduction, striving to make these practices sustainable. Efforts are made to use natural resources, energy, raw materials, and materials efficiently, and full compliance with all legal requirements related to energy is ensured. Ensuring the continuous improvement of energy performance is a fundamental policy for us.