Corporate Ethical Values Policy

Our Basic Ethical Principle;

As KDS Press Casting Industry;    

•    To serve with "Business Ethics" and "Brand Value" created by 40 years of sectoral experience,

•    To act on the axis of transparency, openness and honesty in all our business processes and in all our relations with our employees and stakeholders,

We accept it as our primary ethical principles.

Objective;

This policy determines the application standards and labor norms of the rules of behavior to be followed by all employees, regardless of their expertise, qualifications and position, aiming to provide humane working conditions with KDS Pres Döküm San. A.Ş.'s Code of Conduct determines the labor norms with the application standards of the rules of conduct that must be followed by all employees regardless of their expertise, qualifications and position, aiming to provide humane working conditions. Our norms regulate the situational behavior of employees according to the principles of morality, good faith, honesty and justice and ethical working principles in line with the goals set by our Company.

Scope;

Corporate ethical values policy KDS Pres Döküm San. A.Ş. covers all employees, suppliers and customer relations. The Human Resources Department is responsible for the implementation of this policy, and the General Manager and Management Staff are responsible for supporting the implementation of the policy. B Implementation of these principles KDS Pres Döküm San. A.Ş. is the guarantee of its company identity.

Basis;

•    Turkish Constitution
•    Universal Declaration of Human Rights
•    United Nations Universal Declaration of Human Rights
•    International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work
•    Internationally Accepted Labor Practices
•    Relevant national and international legislation

Definitions;

Child Laborer: A person under 15 years of age.

Young Worker: A person between the minimum working age (15) and 18 years of age. Interns and apprentices. 

Corruption: The misuse of the authority held by virtue of one's position, directly or indirectly, for the purpose of gaining any kind of profit. 

Bribery: Receiving or giving a fee in exchange for favoritism and favor in official affairs. 

Discrimination: Treating individuals and groups differently than others because of a characteristic they actually have or are assumed to have.

Mobbing (Psychological harassment) : A set of hostile and unethical behaviors that are repeated frequently by a single person or group in a systematic effort to wear down an employee.

Organization: Communities established by workers to solve their problems related to working life, to protect and develop their common interests and rights.

Forced Labor: Forced labor against one's free will.

Harassment and Abusive Behavior: A set of behaviors that threaten the physical, mental and emotional limits of a person.

Confidential Information: Any data that should not go outside the organization.

Application;

Code of Ethical Behavior:

1.The personnel working in our factory are selected according to their free will.

2.Company practices comply with all applicable laws and regulations regarding employment and working life. Employees fulfill all legal requirements within the scope of their activities and act in accordance with legal regulations.

3.A safe and healthy working environment will be provided by taking into account the general information in the industrial field and any special hazards specific to the work. Appropriate measures will be taken to prevent accidents and injuries and to minimize the health risks exposed in the specific work environment to the lowest possible level.

4.All employment decisions are based entirely on the qualifications of the individual, including education, training, experience, skills and abilities, as far as they are relevant to the requirements of a specific job description.

5.The private and family life and personal space of all employees shall be respected. All kinds of verbal, written and electronic communication between individuals cannot be recorded, shared with others and/or published without their own consent.

6.Personnel personal and accrual information arising from the business relationship at the workplace and which may be necessary for the continuation of the business relationship cannot be used for purposes other than their purpose and cannot be shared with third parties without the consent of the persons.

7.Forced labor in exchange for debt, bonded labor or any other form of forced labor is prohibited.

8.No one under 15 years of age or under the age of completion of compulsory education (whichever is higher) shall be employed.

9.No apprentices and vocational students (trainees) shall be employed in our factory under the age of 15 or under the age of completion of compulsory education (whichever is higher).

10.Our factory will comply with all regulations and requirements of apprenticeship or vocational training programs and will certify to auditors that these are legally recognized programs.

11.KDS Pres Döküm San. A.Ş. is against all kinds of bribery and corruption. It is absolutely unacceptable to take or give bribes regardless of the purpose.

12.Through bribery or corruption, KDS Pres Döküm San. A.Ş. through bribery or corruption, the business relationship should not be continued.

13.Our employees should not accept cash or cash equivalent gifts, regardless of their amount, or borrow money from suppliers, consultants, competitors or customers.

14.Our employees are responsible for complying with competition laws in all markets in which we operate and not violating the intellectual property rights of third parties.

15.KDS Pres Döküm San. A.Ş. employees must avoid any conflict of interest and / or any kind of interest belonging to themselves or third parties.

16.KDS Pres Döküm San. A.Ş. in no way compromises the violation of money laundering laws.

17.Our employees should not enter into relationships with all third parties, including customers and suppliers, that may cause conflict of interest in the offer and acceptance of gifts, invitations and hospitality.

18.KDS Pres Döküm San. A.Ş. approaches non-governmental organizations and political parties with the principles of integrity, honesty and impartiality.

19.KDS Pres Döküm San. A.Ş., we consider information security among our top priorities and act in accordance with our company's Information Security Rules and the Law on the Protection of Personal Data (KVKK).

20.Our employees may organize entertainment and dining activities within reasonable limits in the business world and participate in similar activities. In organizations such as seminars, etc. attended on behalf of the Company, gifts such as prizes, mattresses, etc. with symbolic value and as a memory of the day may be received in addition to money.

21.Our employees may not give gifts to organizations and individuals with whom they have business relations, except for gifts prepared by the Company for promotional purposes. 

22.KDS Pres Döküm San. A.Ş. employees should stay away from relationships and situations that may create potential or actual conflicts of interest.

23.KDS Pres Döküm San. A.Ş. It is unacceptable for employees of KDS Pres Döküm San. A.Ş. to gain personal benefits from persons and organizations with whom they have a business relationship in a corporate sense by taking advantage of their positions within the company.

24.It is unacceptable to discriminate among employees within the organization based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons.

25.In addition to all kinds of immunities of employees, physical, sexual and emotional immunities are also observed.

26.KDS Pres Döküm San. A.Ş. Human Resources policies and practices ensure that all other practices such as recruitment, promotion - transfer - rotation, performance management, remuneration, rewarding, social rights, training, etc. are fair.

27.All overtime work will be applied within the framework of free will and voluntary principle. Each worker's daily working time, how often they work overtime and how many hours they work will be under control. Weekly working hours will not exceed 45 hours, excluding overtime.

28.Any violation of inviolability through physical, sexual and/or emotional harassment against our employees or persons with whom we have a business relationship by our employees at the workplace or any place where they are present due to work cannot be tolerated. Possible negative attitudes and behaviors towards those who report such violations or assist during the investigation are considered as a violation of our code of ethics.

29.Systematic and planned behaviors that aim to alienate the targeted person from work, reduce his/her performance, and cause him/her to resign, which can be considered within the scope of psychological harassment (mobbing), cannot be tolerated.

30.Clean toilet facilities and drinking water will be provided and, if applicable, sanitary facilities will be provided for the storage of foodstuffs.

31.KDS Pres Döküm San. A.Ş., it is the common responsibility of all our companies and employees to use information effectively, to share it correctly and to ensure the confidentiality, integrity and accessibility of information in this process. 

32.Confidential information; KDS Pres Döküm San. A.Ş.'s trademarks, etc. intellectual rights, including all kinds of innovations, database, printed communication materials, processes, advertising, product packaging and labels and plans (marketing, product, technical), business strategies, strategic partnerships and information on partners, financial information, personnel information, customer lists, product designs, management knowledge (know-how), specifications, identity of potential and actual customers, information on suppliers, etc. It includes all kinds of written, graphic or machine-readable information. 

33.Identifying information such as passwords, user codes, authorizations, etc. used to access company information systems must be kept confidential and must not be disclosed to anyone other than authorized users. 

34.This information cannot be disclosed to third parties unless disclosure is mandatory in accordance with Official Authorities and Legislation. This information cannot be changed, copied or destroyed. Necessary measures are taken to ensure that information is kept carefully, stored and not disclosed. 

35.Company confidential information should not be discussed in public places such as dining halls, cafeterias, elevators, service vehicles, etc. 

36.Even if it is not stated in writing that it is confidential, it is necessary to protect the confidentiality of all kinds of information and documents of the nature specified in Article 30, and our employees are responsible for this responsibility at KDS Pres Döküm San. A.Ş. during their employment at KDS Pres Döküm San. A.Ş. and in case they leave the job. 

37.Unfounded statements and/or rumors about individuals or institutions cannot be made. 

38.Wage confidentiality is essential; it cannot be shared with third parties in any way. 

39.Details about all rules can be found in KDS Pres Döküm San. A.Ş. Code of Ethics and Implementation Principles are published on our website.

Awareness/Recognition of the Procedure;

The Human Resources Department is responsible for ensuring that;
•    Publishing and announcing this Procedure to existing employees and newly recruited personnel, and introducing the norms it contains, 
•    Training is given to every new employee. It is repeated annually for existing employees and communicated through the internal communication platform. 
•    In case of violation of these norms, employees are informed about the notification channels, 
•    When possible changes to the procedure come into force, informing employees about the changes within one month at the latest,

Whistleblower Notification;

As KDS casting, we keep the sustainable implementation and adoption of our code of ethics among our priorities in order to maintain our strong culture of ethical behavior. We guide our employees to report any legal, policy or ethical violations that they have detected or suspected in good faith on the basis of confidentiality, without any retaliation or victimization.

The issues that our employees can report within the scope of whistleblowing notification are listed below:

•    Violation of laws and regulations to which the Company is subject 
•    Violation of company policies 
•    Violation of the code of ethical conduct

Examples of reportable matters include, but are not limited to, the following:

•    Corruption (blackmail, bribery, conflict of interest, fraud, money laundering, etc.) 
•    Anti-competitive practices 
•    Information management breach 
•    Modern slavery and human trafficking crimes 
•    Discrimination and harassment 
•    External stakeholder human rights violations 
•    Food safety violation

In order for the whistleblowing report to be investigated quickly and efficiently, as much detailed information as possible should be provided. A whistleblowing report may be made anonymously. However, this may prevent the whistleblowing report from being investigated in detail, and an investigation may not be possible. Making whistleblowing allegations with a name will enable the source to be contacted if necessary and the allegation to be investigated more quickly and efficiently. Detailed definitions are provided in the Emergency Information Flow (Escalation) Procedure (PR.37) and Escalation Matrix (SF.398).

The identity of the whistleblower must be kept confidential unless authorized or required by law. All necessary steps must be taken to protect the whistleblower from retaliation and victimization of any kind. Any action by any person that could result in victimization against the whistleblower or any other person involved in a whistleblower investigation must not be tolerated and appropriate disciplinary action must be taken. 

The employee must have reasonable grounds to suspect that the information disclosed in a whistleblowing report is accurate. In this context, if the information provided in good faith is found to be false, no disciplinary action shall be taken against the whistleblower. Making a deliberately false and misleading claim, on the other hand, is considered a serious matter that may result in disciplinary action as it would be a violation of our Code of Business Conduct. 

Each employee is responsible for knowing and applying the rules in the Procedure and encouraging others to do so.