All employees of our company have adopted the following principles in accordance with quality policy.

• Change-oriented and visionary management.
• Become integrated with employees.
• Make quality a lifestyle.
• Customer satisfaction.
• Create resource.
• Continuing training.
• Continuous improvement and productivity.
• Respect to people and environment.
• Reduce occupational health and safety risks.
• Assume to comply with legal and other conditions.
• Protection and productive use of energy and natural resources, reduction of environmental burden.

It is aimed to be a guide to company employees in their decisions when they carry out their duties and in their behaviours with Business Ethics and Rules of Morality based on this quality policy.

Acting of attitudes and behaviours that will provide the cultural integrity of our company is expected from our all employees.

All employees, including temporary employees, are obliged to comply with the Business Ethics and Rules of Morality.

Declaring of the Business Ethics and Rules of Moralities to all employees, ensuring that employees are given necessary attention to these rules and following of the rules are the main tasks and responsibilities of all employees in the manager role.

Responsibility of reading, understanding by employee and documentation of implementation commitment of the latest version of Business Ethics and Rules of Morality document belongs to employee’s manager.

Kutes Metal Ind. and Trade Inc. values its employees and respects their rights and protect them. In this context;

• Seek the qualification as a single measure in recruitment, ensure equality in opportunity without discrimination.
• Bring the most qualified and experienced professionals who will take our company further.
• Provide maximum benefit from the capacities, power and creativity of employees.
• Ensure possibility and equality in opportunity for training, leading and development of employees.
• Use equitable and competitive compensation policies, effective and objective performance evaluation systems.
• Ensure the continuity of labour peace.
• Ensure safe working conditions for employees in all respects where are clean, healthy and necessary of work safety measures were taken.
• Build a working environment where cooperation and cohesiveness are the most important factor, encourage transparency and mutual respect.
• Not allow any kind of harassment in the working place.
• Evaluate and respond to employees' opinions and suggestions and take measures to increase motivation.
• Not share special information about employees without the employee's permission and knowledge except for legal obligations.
• Be respectful of human rights, create basic principles in terms of relations with employees.

3.1 Government Relations

• Comply with all related laws, rules and regulations in countries where we are operating and will be active.
• Manage, record and report all operating activities and accounting system in accordance with the laws.

3.2 Customer and Supplier Relations

• Create value for customers, meet their demands and requirements at the highest level.
• Present quality products and services and follow stable policies about quality.
• Create a long-term trust environment in relations with customers.
• Aim to be the first choice by increasing customer satisfaction in sales and after sales process.
• Not give misleading and incomplete information to customers.
• Create mutual value in business relations with suppliers.
• Carry out communication with suppliers clearly, directly and correctly.
• Decide with objective criteria when selecting supplier.
• Comply with reasonable privacy and job safety rules requested by the supplier during supplier inspections and visits.

3.3 Competitor and Competitive Relations

As Kutes Metal, we compete with our competitors only in legal and ethical areas and avoid unfair competition.

Remember our company with professionalism, honesty and confidentiality is the primary responsibility of all our employees. B In this context, the expectations from company employees are as follows:

• Always comply with the law.
• Fulfil duties within the framework of basic ethic and human values.
• Behave in good faith and understanding in order to provide mutual benefit in all relations.
• Not derive an improper personal benefit in any way from people and organizations, not to accept or give bribes each whatever purpose.
• Perform related business ethics and rules of morality and all procedures supported these rules in continuing duties.
• Not to be in behaviour, in the declaration or in correspondence that leave the company under contract unless expressly authorized.
• Not to be in behaviour that annoys and/or damages other employees, not disorder work harmony.
• Pay attention to all tangible and intangible assets of company including information and information systems as personal property, protect them from possible loss, damage, misuse, abuse, theft and sabotage.
• Not use working time and company resources directly or indirectly for personal benefit and/or political activity and profit.

4.1. Asset and Information Management

4.1.1. Intellectual Property Rights

• Ensure that operations are initiated and completed on time legally to be able to guarantee the intellectual property rights of newly developed processes.
• Avoid unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies –knowingly-.

4.1.2. Information Management

• Ensure that all legal records are kept in correctly way.
• Not answer/approve information requests from third parties within the classified category for the company without senior management approval.

4.1.3. Security and Crisis Management

• Take necessary precautions to protect company employees, information and information systems, factories and administrative offices against possible terror, natural disasters and abuses.
• Make necessary crisis planning related to emergency crisis management that will be organise in case of terrorism, natural disasters etc. and ensure business continuity with minimum loss during crisis in this way.
• Take all kinds of precautions to prevent theft or damage of company assets.

4.1.4. Privacy

• Act with the consciousness that agreements with business partners, financial and trade secrets of the Company, information that will weaken the company's competitive power, personnel rights and information are in in the "privacy" framework, ensure their protection.
• Not share the information learned at the job and the documents they possess with the unauthorized persons and authority inside and outside of the company for whatever purpose, not use directly or indirectly for speculative purposes.
• Not use companies where they work, the customers of these companies, non-public information about other people and organizations in no way out of intended purpose, not share with third parties without obtaining the necessary permissions.

4.2. Avoiding Conflicts of Interest

Non-use of company’s resources, name, identity and power, avoiding situations that negatively affect name and image of the institution are the most important responsibility of all employees and following code of practices determine conflict situations in their private lives and the necessary principles to be applied in this situations while company employees perform duties and due to business relationships.

4.2.1. Not taking action in favour of itself and its relatives

Employees must inform the situation that they have own shares in another company or participate to their investment while starting work if there is. This issue is particularly questioned in business negotiations with candidates. Employees report to senior manager the changes that may occur over time in this situations and suchlike issues that can be perceived as a conflict of interest and the information is transmitted up to at least two high-level manager.

• Not provide unfair advantage in favour of itself, its relatives or third persons by profiting title and warranty.
• Take care not to fall into conflict of interest with currently worked institution in personal investments to be made.
• Take care that Personal investments to be made or any interests out of business activity don’t prevent to carry out his continuing duty in Kutes Metal Ind. Trade Inc. in terms of time and giving attention and avoid the occurrence of such situations.
• Give information to management in case of first-degree relatives of employee and people who are in the first-level decision-making position for the same job in the customer or supplier company.

4.2.2. Participation in representations and organization invitations

Participation in invitations like sporting activities, domestic/abroad visits etc. that can be perceived or be effective in making decisions except conferences, receptions, promotional events, seminars, etc. open to general participation which conducted by persons or institutions in a business relationship or carry potential is subject to Operational General Manager approval.

4.2.3. Receiving and Giving Gifts

In carrying out the relations with private or public persons and organizations seeking to establish or maintain a business relationship with the Company;

• Not accept and offer any gift that create impression of the presence of an irregularity, may cause dependency relationship or can be perceived like this, except materials, that given in accordance with commercial tradition and mores or has the characteristics of memory/promotional.
• Not claim, not offer to third parties, not accept when offered any discounts or benefits that may be perceived as unsuitable from suppliers, customers, Group companies or third parties.

Our company has aimed providing occupational health and safety entirely at work and on the job.

• Employees act in accordance with the rules and regulations for this purpose and take necessary precautions.
• Employees will not keep any goods or materials in the workplace which are dangerous to the workplace and/or workers or illegal.
• Employees will not keep drugs, addictive substances, restricting or removing agents of mental or material faculties except for those kept based on a valid medical report, will not work at workplace and within the scope of work while they are under the influence of these substances.

Our company does not donate to political parties, politicians or political candidates. Demonstrations, propaganda and similar intentional activities in these scopes are not allowed within the boundaries of the workplaces. Company resources (such as tools, computers, e-mail) cannot be allocated for political activities, political commentaries.

7.1. Reporting Liability of Violations

If employees learn or suspect that the Ethical Conduct Rules or the laws and regulations to which the company is subject are violated, they are obliged to communicate this firstly to the manager or the Senior Manager and/or the General Manager depends on the situations.

Disclosure to the third party of the notice that the person has made in the workplace to affect the peace or business relations in a negative way will definitely be avoided. The notification mechanism must be in line with the interests of the company. It is very important that the notifier is free from intentions such as gossiping about the reported person or trying to negatively affect his/her career. In this respect, confidentiality, objectivity and compliance with ethical rules are extremely critical issues in the process of denunciation and investigation. It is mandatory that people who are both notified and who manage the related process have maximum care and attention. When intentional notices which are in characteristics of lie and/or reflection are detected, it is commended as a violation of ethical rules.

7.2. Ethical Behaviour Board

The Ethics Behaviour Board will work to better evaluate inappropriate situations about ethical rules, to apply disciplinary practices and to ensure parallelism in applications.

The Ethics Behaviour Board consists of the following persons:   

• General Manager. (President of the Company Ethical Behaviour Board)
• Manager of Human Resources and Administrative Affairs.
• Legal Advisor.
• Management Representative.

7.3. Discipline Practice

The following disciplinary punishments apply after violations of Ethical Behaviour Rules:

• If there is an abuse that is found to have been done purposely; discharge and initiate legal action, if necessary, in accordance with the relevant articles of labour law. (Beneficial works that the person providing the purposely beneficiary, have done in the past cannot cause a partial or complete indulgence on the decision taken.)
• If there is no abuse or if there is negligence arising from carelessness or ignorance; verbal or written warning according to the event’s effect.