Etik Davranış İlkeleri

Ethical Conduct Principles

Our company, VBT Yazılım (VBTYZ) A.Ş., within the framework of its social responsibilities, places importance on regulations related to the environment, all stakeholders, consumers, and public health. Therefore, it is committed to adhering to the Ethical Conduct Principles that have been established.

OUR BASIC PRINCIPLES REGARDING RELATIONS WITH EMPLOYEES

One of the goals is to bring qualified young people and experienced professionals who will advance our company to our firms,

  • VBTYZ A.Ş. rewards success with fair and competitive wage policies, effective and objective performance evaluation systems and practices,
  • VBTYZ A.Ş. is committed to the principle of basing its employment decisions on necessary qualifications, merit, performance, and other job-related factors,
  • VBTYZ A.Ş. does not tolerate illegal discrimination in employment,
  • VBTYZ A.Ş. aims to increase employee loyalty to the company by providing equal opportunities in promotion, education, development, and rewards,
  • Continuity of workplace peace is essential at VBTYZ A.Ş.,
  • VBTYZ A.Ş. creates and sustains a work environment that promotes transparency and mutual respect,
  • VBTYZ A.Ş. does not permit any actions, practices, or behaviors that are degrading, intimidating, and hostile under any circumstances. It absolutely does not tolerate harassment in workplaces,
  • VBTYZ A.Ş. values the opinions and suggestions of its employees. All feedback, suggestions, and views from employees are evaluated and responded to, and measures are taken to increase motivation afterward,
  • VBTYZ A.Ş. keeps the personal information of employees confidential and does not share it with third parties without the employee's consent unless there is a legal obligation,

OUR BASIC PRINCIPLES REGARDING RELATIONS WITH SUPPLIERS

  • Mutual value is created in relationships with suppliers,
  • Communication with suppliers is carried out openly, directly, and in accordance with laws and procedures,
  • Objective criteria are used in supplier selection,
  • In supplier audits and visits, the reasonable confidentiality and safety rules requested by the supplier are followed,

OUR BASIC PRINCIPLES REGARDING RELATIONS WITH SHAREHOLDERS

  • VBTYZ A.Ş. protects the legally determined rights and interests of shareholders,
  • It makes the necessary efforts to create value in return for the resources provided by shareholders, distributes the resulting profit to the shareholders or directs it to investment,
  • All necessary efforts are made to represent the “VBTYZ A.Ş.” brand in the best possible way in society and to increase its reputation,
  • VBTYZ A.Ş. maintains continuous communication with its stakeholders, benefits from their criticism and suggestions, and ensures the continuation of positive relationships,
  • It ensures the full, timely, and accurate disclosure of issues that need to be disclosed to shareholders and the public regarding the companies,
  • VBTYZ A.Ş. ensures that it is managed within the principles of trust and honesty, which have been ongoing since its establishment, and manages its resources, assets, and working time with an awareness of efficiency, aiming for sustainable growth and profitability,
  • For shareholders to have equal and simultaneous information under equal conditions, VBTYZ A.Ş. ensures that its employees who have access to “insider information” sign a Confidentiality Agreement,

OUR BASIC PRINCIPLES REGARDING RELATIONS WITH THE PUBLIC AND OTHER COUNTRIES

  • VBTYZ A.Ş. is respectful and transparent to all institutions of the state,
  • VBTYZ A.Ş. complies with all relevant laws, rules, and regulations in all countries where it operates or will operate. It manages, records, and reports all business activities and accounting systems fully and appropriately according to the laws,

OUR BASIC PRINCIPLES REGARDING RELATIONS WITH COMPETITORS AND COMPETITION

  • VBTYZ A.Ş. does not engage in any agreements or coordinated behaviors directly or indirectly with competitors or other individuals or entities that have the purpose or effect of preventing, disrupting, or restricting competition, or that could have this effect, outside the limits permitted by legislation,
  • It does not abuse its dominant position when it is dominant in a particular market alone or with other undertakings. It does not engage in discussions and exchange of information with competitors aimed at jointly determining market and/or competition conditions,
  • In association, assembly, chamber, professional organizations, etc., meetings, and other private or professional meetings and discussions representing the company, every kind of discussion and transactions that may lead to or be characterized as the above-mentioned situations are avoided,

OUR BASIC PRINCIPLES REGARDING EHS AND SOCIAL PERFORMANCE

  • VBTYZ A.Ş. continuously develops its environmental policies and ensures their effective implementation,
  • VBTYZ A.Ş. acts for the benefit of our country and the world and sets an example of corporate citizenship with our employees, operators, and suppliers,
  • While maintaining its commitment to the aim of not harming people and protecting the environment, VBTYZ A.Ş. aims to develop services compatible with these objectives,
  • VBTYZ A.Ş. aims to gain the trust of customers, shareholders, and society to be a good neighbor and contribute to sustainable development,

OUR BASIC PRINCIPLES REGARDING SOCIAL RESPONSIBILITY

  • VBTYZ A.Ş. supports studies that will contribute to economic and social development within a program framework,
  • It shows sensitivity to issues concerning society and provides support for the positive development of society,
  • VBTYZ A.Ş. takes ownership of projects, especially in the field of education, implemented for the development of society, and adopts and enshrines this approach as a principle,

OUR BASIC PRINCIPLES REGARDING COMBATING CORRUPTION

  • VBTYZ A.Ş. does not tolerate activities such as bribery, insider trading, market abuse, fraud, or money laundering.
  • Facilitation payments are also considered bribes, and making such payments is never acceptable.

ETHICAL CONDUCT PRINCIPLES THAT EMPLOYEES MUST FOLLOW

The primary responsibility of all VBTYZ A.Ş. employees is to ensure that the VBTYZ brand is associated with experience, honesty, and trust and to carry it forward. In this context, the expectations from VBTYZ A.Ş. employees are:

  • Always comply with the law,
  • Perform their duties within the framework of fundamental moral and human values,
  • Under no circumstances gain unjust benefits, accept or give bribes from or to individuals or organizations,
  • Act in accordance with the relevant business ethics rules and all supporting application principles in the duties carried out,
  • Not to engage in any behavior, statement, or correspondence that would commit the company unless explicitly authorized,
  • Not to engage in behaviors that would disturb and/or harm other employees and not to disrupt the order of the working environment,
  • Take care of all tangible and intangible assets of the company, including its information and information systems, as if they were personal property and protect them against potential loss, damage, misuse, abuse, theft, and sabotage,
  • Do not use or allow the use of working time and company resources directly or indirectly for personal gain and/or political activity and interest,
  • Ensure that legal procedures are initiated and completed in a timely manner to secure the intellectual property rights of newly developed products, processes, and software,
  • Avoid unauthorized use -knowingly- of patents, copyrights, trade secrets, trademarks, computer programs, or other intellectual and industrial property rights belonging to other firms,
  • Ensure that all legal records are kept in the form required by law,
  • Obtain written approval from senior management to respond to information requests from third parties that fall into the category of confidential information for the company,
  • Exhibit the necessary diligence to ensure that the declarations made and reports presented by the company are accurate,
  • Take necessary measures to protect company employees, information and information systems, business and administrative facilities against potential terrorism, natural disasters, and malicious attempts,
  • Plan crises management to ensure business continuity with minimal loss in cases of terrorism, natural disasters, etc.,
  • Take all necessary measures to prevent the theft or damage of company assets,
  • Act with the awareness that the financial and commercial secrets of VBTYZ A.Ş., the information that would weaken the competitive power of the company, the rights and information of personnel, and the agreements made with business partners are within the scope of “confidentiality”, and ensure their protection and confidentiality,
  • Do not share information and documents learned due to the job with unauthorized persons and authorities inside or outside the institution for any purpose, and do not use them speculatively (directly or indirectly),
  • Not use non-public information related to the companies they work for and their customers and other people and companies they do business with for any purpose other than the intended purpose, and do not share it with third parties without obtaining the necessary permissions,
  • Avoid conflicts of interest (Conflict of interest refers to any situation in which employees have any benefit or any material or personal interest that affects or may affect their impartial execution of their duties or provides benefits to themselves, their relatives, friends, or people or organizations they are associated with.),
  • Do not allow personal and private thoughts to influence decisions made within the VBTYZ A.Ş.,
  • Do not provide unfair benefits to themselves, relatives, or third parties by taking advantage of titles and authority,
  • Ensure that personal investments do not lead to a conflict of interest with the institution they currently work for,
  • Ensure that personal investments or any non-business activities do not hinder their performance in their current duties at VBTYZ A.Ş., and avoid such situations that prevent focusing on primary duties,
  • Inform management and obtain approval if employees and their relatives have a first-degree relationship with individuals in decision-making positions in companies that are customers or suppliers for the same business,
  • Inform management if they learn that their relatives have shares or material interests in another company with which there is a commercial relationship,
  • Participation in events such as conferences, receptions, promotional activities, and seminars organized by individuals or institutions with whom there is or potential for a business relationship is subject to the approval of the General Manager. Participation in sporting activities, domestic/international trips, and similar invitations that are or may be perceived as influential in decision-making is subject to the approval of the General Manager,
  • The sending of gifts to and acceptance of gifts from customers, suppliers, or operators with whom there is or potential for a business relationship is subject to the written approval of the General Manager,

In managing relationships with private or official individuals and organizations who want to establish or maintain a business relationship with VBTYZ A.Ş.;

  • Do not accept or offer any gifts other than those given in accordance with commercial traditions, customs, and materials of souvenir/promotion nature that create an impression of irregularity, can lead to a dependency relationship, or may be perceived as such,
  • Do not request or offer any discounts or benefits from suppliers, operators, tenants, customers, Group companies, or third parties that may be perceived as inappropriate, and do not accept such offers when made,

POLITICAL ACTIVITY

  • VBTYZ A.Ş. does not make donations to political parties, politicians, or political candidates without a board decision. Demonstrations, propaganda, and similar actions for such purposes are not allowed within the boundaries of workplaces. Company resources (such as vehicles, computers, emails) cannot be used for political activities.

OUR BASIC PRINCIPLES REGARDING OCCUPATIONAL HEALTH AND SAFETY

  • Our company aims to fully ensure occupational health and safety at the workplace and on the job. Employees act in accordance with the rules and instructions set for this purpose and take the necessary measures.
  • Employees will not keep any items or substances at the workplace that could pose a danger to the workplace and/or workers or are illegal.
  • No employee or operator, even if licensed, can carry weapons, etc., at the workplace.
  • Except for those kept based on a valid doctor's report, employees will not keep, use, or consume drugs, addictive substances, or substances that restrict or eliminate mental or physical faculties at the workplace. They will not work or drive under the influence of such substances.

IMPLEMENTATION PRINCIPLES OF ETHICAL CONDUCT RULES

Obligation to Report Violations:

  • Employees are obliged to report to their immediate superior (first manager), the General Manager, and/or the Chairman of the Board of Directors if they learn or suspect that the Ethical Conduct Principles of VBTYZ A.Ş. or the laws and regulations to which the company is subject are being violated.
  • The disclosure of the notification to third parties that would negatively affect the individual's peace at the workplace or business relationships will be strictly prevented.
  • The notification mechanism should be in line with the interests of the company. It is crucial that the notifier is free from intentions such as gossiping about the reported person or trying to negatively affect their career. Confidentiality, objectivity, and compliance with ethical rules are critical during the reporting and investigation process. Both the notifier and the individuals managing the process must pay utmost attention to this issue.
  • Intentional notifications of a false and/or defamatory nature will be regarded as a violation of ethical rules.

DISCIPLINARY PRACTICES

The following disciplinary penalties will be applied after violations of ethical conduct rules:

  • As a result of a decision by the disciplinary board, if it is determined that the abuse was done knowingly, the personnel will be dismissed (in accordance with the relevant articles of the labor law), and legal action will be initiated if necessary. The useful work done by the person who knowingly gained unfair benefits cannot partially or completely constitute a reason for forgiveness on the decision made.
  • If there is no abuse or the negligence is due to carelessness or ignorance, a verbal or written warning will be given according to the impact of the incident.