Anti-Bribery and Anti-Corruption Policy
Purpose
It is the anti-bribery and anti-corruption policies of the Anti-Bribery and Anti-Corruption Policy, which are also included in the Tibet Group of Companies Business Code of Ethics.
Scope
The anti-bribery and anti-corruption policy covers:
All employees of Tibet Group of Companies including the Board of Directors,
Companies from which we outsource goods and services and their employees, as well as people and organizations (business partners) working on behalf of Tibet Group of Companies including consultants, lawyers and external auditors.
This Policy
is an integral part of Corporate Governance Principles approved by the Board of Directors of Tibet Group of Companies and disclosed to the public, and the Business Code of Ethics of Tibet Group of Companies,
and Human Resources Practices.
Definitions
Corruption: It is the misuse, of the authority held due to the position, for the purpose of gaining any advantage directly or indirectly.
Bribery: It is a person's gaining advantage or providing advantages to others within the framework of an agreement reached with a third person so that such person acts in breach of the requirements of his/her duty by doing a work, having it done, not doing a work, speeding it up, slowing it down by means of providing, offering or promising, demanding or accepting benefits, directly or through intermediaries.
Bribery and corruption may occur in the following ways:
Cash payments,
Political or other donations,
Commission,
Social benefits,
Gift, entertainment,
Other benefits
Duties and Responsibilities
It is the authority, duty and responsibility of the Board of Directors to enforce and update the Anti-Bribery and Anti-Corruption Policy.
In this context,
The Human Resources and Management Consultants of the Directorate General must advise the Board of Directors for establishing an ethical, reliable, legal and controlled working environment,
Senior management must evaluate risks and establish the necessary control mechanisms in compliance with the principles to be defined by Board of Directors,
Audit Directorate, Financial Affairs Directorate, Legal Consultants, Accounting Directorate and Finance Directorate must follow whether operations of Tibet Groups of Companies are carried out safely and in compliance with legal regulations,
In case policies, rules and regulations are not complied with, the report, review and sanction mechanisms must be determined and operated.
The employees of Tibet Group of Companies are liable to:
comply with established policies of the Board of Directors,
manage effectively the risks associated with their business operations,
work in accordance with the relevant legal regulations and the practices of Tibet Group of Companies,
and inform the Board of Directors if they encounter with a conduct, activity or practice which is in breach of the Policy.
The Companies from/to Which Goods and Services are Bought and Sold and Business Partners
The companies from/to which goods and services are bought and sold and business partners must comply with the Policy principles and other relevant regulations. Relations with persons and institutions failing to comply these conditions shall be terminated.
5.1 Selection of Companies and Business Partners
In addition to criteria such as experience, financial performance and technical sufficiency, the Senior Management takes into account morality and a positive background in this field during the selection of the companies from/to which goods and services are bought and sold and business partners. The companies and the business partners about which negative information with regard to bribery or corruption is available will not be collaborated any way even if they meet other requirements. The responsibility for making necessary research and evaluation during this process before establishing a business relationship primarily belongs to the senior management. Audit Department evaluates, during its audits, whether such terms are followed or not.
5.2 Concluding an Agreement with Companies and Business Partners
The contracts and agreements to be made with the companies and business partners about which positive information is available, and which meet other criteria, include the following provisions:
Full compliance with the principles indicated in the policy and other relevant regulations must be ensured,
Employees must internalize these principles and act accordingly,
It must be ensured that employees receive trainings about the Policy in certain periods,
Employees must be reminded regularly about their notification obligations and the regulations in this field and they must be encouraged to notify in case they encounter such situations,
The work and contracts in force will be terminated for justified reasons if a situation contrary to the Policy emerges in the contract. Our Policy and Procedures:
6.1 Bribery and Corruption
Tibet Group of Companies is against all kinds of bribery and corruption. It is forbidden for the persons covered by the Policy to offer money or anything of value to obtain an illegal and unethical benefit, or obtain a similar benefit from other organizations and persons, or get involved in any illegal and unethical behavior that could be considered as bribery or corruption even if it is in favour of the Company. Accepting or giving a bribe can never be accepted for any purpose.
Business relationships with third persons wishing to do business with Tibet Group of Companies through bribery or corruption have to be terminated.
6.2 Gift
A gift is a product generally given by customers or persons, with whom a business relationship is established, as a means of thanking or commercial courtesy, and which does not require a financial payment.
All kinds of gifts offered or given to third persons by Tibet Group of Companies must be offered in public, with good faith and unconditionally. Our employees are obliged to refuse gifts such as goods, services, cash or checks that may come from a third party, and that may or intend to affect our company's preferences and decisions, regardless of their value. Similarly, our employees do not offer or make such requests for gifts, entertainment or other gifts that may or intend to affect the decisions of other institutions about our company. The gifts that can be given in this way are defined by our Code of Ethics Policy.
Even if it is within this scope, gift acceptance must not become frequent, and the Human Resource Department and Senior Management have to be informed about the gift by the employee, who accepts gift, through his/her immediate supervisor.
6.3 Facilitating Payments
The persons and institutions within the scope of this Policy may not offer facilitating payments to guarantee or speed up a routine transaction or process (obtaining authorization and license, obtaining a document, etc.) with government agencies.
6.4 Donations
The ethical rules regarding the support of employees of Tibet Group of Companies to the charity organizations by the donations they collect independently are defined in our Code of Ethics Policy.
Correct Recording
The terms which Tibet Group of Companies must follow in relation to accounting and recording system are regulated with legal regulations. Accordingly:
All kinds of accounts, invoices and documents belonging to relations with third parties (customers, suppliers, etc.) must be recorded and kept in a complete, accurate and reliable manner,
Falsification and distortion must not be performed on accounting or similar commercial records related to any transaction.
Notification of Policy Breaches
If there is any opinion or suspicion that an employee or a person acting on behalf of Tibet Group of Companies breaches this Policy, the Human Resources Directorate and Directorate General of Sultanlar Group must inform the Board of Directors about it.
Tibet Group of Companies encourages an honest and transparent approach; supports any employee or person acting on behalf of Tibet Group of Companies who expresses his/her sincere concerns with good faith, and keeps such notifications secret. No employee shall be subject to pressure or punishment for the notification of a violation of the Code of Ethics, and if the notifying person is subject to such treatment, he/she is expected to inform this to the Human Resources Directorate.
Policy Breaches
In the cases which are or could be contrary to the Policy, the matter is reviewed by the Human Resources Directorate and the Board of Directors, and necessary sanctions are implemented if inappropriate acts are detected.
The contracts made with the companies from/to which goods and services are bought and sold, and with the persons and organizations acting on behalf of Tibet Group of Companies have the provisions that the works/contracts in force will be unilaterally terminated by Tibet Group of Companies for justified reason if any conduct, attitude or activity contrary to the Policy is detected in such contracts, and such provisions will be applied without any exemption in case of breach of the Policy.