This agreement has been signed on xxx between Semtrio Eğitim ve Danışmanlık Hizmetleri A.Ş., headquartered at [address], and the sub-supplier [Sub-Supplier Company Name], headquartered at [Sub-Supplier Company Address]. This agreement covers the Supplier Code of Conduct determined by [Semtrio Eğitim ve Danışmanlık Hizmetleri A.Ş.] and which [Sub-Supplier Company Name] agrees to comply with and undertakes to comply with these rules. In cases of non-compliance, the right to terminate the contract / stop the business relationship is reserved.

1. OBJECTIVE

As Semtrio Eğitim ve Danışmanlık Hizmetleri A.Ş., we are proud to create and present the Supplier and Customer Code of Conduct of our organization. With the belief that sustainability and ethical values should be at the center of the business world, our main product is “guidance for sustainable life and business models.” These principles reflect how we integrate sustainability and ethical behavior into our business processes and how these principles are implemented in our relationships with our suppliers and customers. Our goal is to create a sustainable business model and provide a fair, ethical, and ecofriendly business environment for all our stakeholders. These principles underpin our business model and are designed to ensure adherence to the principles of environmental responsibility, social and fair labor practices, effective governance, and ethical business conduct at every stage of our business processes. 

These principles aim to ensure that our company and our business partners act in a way that considers not only the needs of today but also the needs of future generations. We expect our suppliers and customers to integrate these principles into their business processes and accompany us on our sustainability journey.

To build strong, sustainable relationships based on mutual respect, transparency, and long-term cooperation, our principles will be regularly reviewed and updated in the spirit of continuous improvement. Our expectation is that the same care and perspective will be of value to all our suppliers, customers, and business partners. 

Our aim is to develop long-term business partnerships based on mutual value and respect with our stakeholders who adopt and implement these principles. 

Every step towards a sustainable future is of great value to us. We would be honored to see you with us on this journey.

2. REFERENCES 

These codes support our commitment to the targets below: 

• United Nations (UN) Global Compact 10 Principles
• ETI Code of Conduct
• ILO (International Labor Organization)
• UN Sustainable Development Goals (SDGs)

We encourage suppliers to maintain policies, procedures, and practices that address these issues. We expect our suppliers to and support them in implementing efficient management systems utilizing internationally-recognized standards (ISO14001, ISO45001, SA8000, etc.).

3. SCOPE

The Supplier and Customer Code of Conduct covers all our business operations with all our existing and potential suppliers, customers, and business partners.

The approach and compliance with these principles will be used as the main criteria for the selection and evaluation of our suppliers, customers, and business partners. 

4. CODE OF CONDUCT

4.1. Worker and Human Rights 

This section describes in detail our company’s expectations from its suppliers, business partners, and customers in terms of employee rights and workplace conditions. Our aim is to create work environments throughout our supply chain that respect human values and ensure fair working conditions and regular employment.

Child and Young Labor: 

• The minimum working age set by the International Labor Organization (ILO) and local law must be complied with, and child labor at any stage of the workforce must not be used.
• Policies that support young workers’ working hours, health and safety standards, education rights, and personal development must be adopted.

Forced Labor: 

• The hiring, employment, overtime work, and termination of workers must be entirely voluntary.
• It is strictly prohibited to confiscate workers’ personal documents, such as IDs or passports, bond them in debt, or other coercive methods.
• Necessary measures must be taken to prevent forced labor throughout te entire business chain, including suppliers, subcontractors, and business partners.

Fair Wages and Work Shifts:

• Suppliers must pay workers at least the local minimum wage or a wage set in accordance with industry standards.
• Overtime practices must be within legal limits, and workers must be paid fairly for overtime.
• Working hours and breaks must be organized to support workers’ health and well-being.

Freedom of Association and Right to Collective Agreements: 

• The right of workers to join trade unions and engage in trade union activities must be fully supported. Workers must be recognized, respected, and fairly involved in collective contracts.

Discrimination:

• Discrimination based on gender, race, ethnic origin, religion, age, sexual orientation, political opinion, trade union membership, disability, HIV/AIDS, or other personal characteristics must be avoided in hiring, promotion, remuneration, and all other labor practices. Migrant and refugee workers must be granted legally recognized work permits and have the same rights as all other workers.
• Policies and practices supporting diversity and inclusion must be developed and actively implemented.
• Training programs and awareness-raising activities on anti-discrimination must be organized.

Preventing Harassment: 

• Effective measures must be taken to prevent all forms of sexual, physical, and verbal harassment, abuse, and inhumane treatment in the workplace.
• Mechanisms must be established to ensure that harassment cases are handled fairly and swiftly.
• Employees must be provided with training on harassment, and in the event of an incident, a follow-up mechanism must be provided, and necessary disciplinary and legal processes must be carried out.

Occupational Health and Safety: 

• Health and safety standards must be implemented to minimize hazards in workplaces.
• Emergency procedures, first aid equipment, and safety training must be provided.
• Occupational health and safety must be continuously monitored and improved.
• Risk analysis must be conducted and updated according to possible situations.
• Occupational accidents / near misses and root cause analyses must be Followed-up on and recorded.

Diversity and Inclusivity: 

• Employees’ diverse cultural, ethnic, and social backgrounds and sexual orientations must be respected. Women’s participation in the workforce must be supported, and equal opportunity perspectives and practices must be integrated into decision-making processes such as recruitment, remuneration, promotion, etc.
• Training programs on diversity and inclusion and events that encourage employee participation must be organized and made part of the business culture.

4.2. Ethical Work Practices 

This section addresses in-depth the expectations of our suppliers, stakeholders, customers, and business partners regarding business ethics and transparency. Our goal is to ensure that high ethical standards are maintained in all our business relationships.

Compliance with National/International Regulations and Conventions: When conducting operations, the laws of each country in which they operate must be strictly observed, as well as the rules of international law, international trade agreements, and conventions. This ranges from local labor standards to environmental regulations, import and export laws, and consumer rights.

Compliance with Fair Competition Law: All activities that prevent, distort, or restrict fair competition and that are inequitable should be refrained from. It is expected to act in accordance with fair competition in actions limiting competition such as price setting, market sharing, and monopoly creation. Adherence to the principles of honesty, transparency, and equality is required. 

Fighting Bribery and Corruption: All forms of bribery and corruption must be avoided. This includes behavior such as offering, giving, receiving, or accepting bribes and gifts, directly or indirectly, to any government official, customer, or business partner. Transparent business relationships and integrity are core values to be demonstrated in this area. 

Fighting Money of Unknown Origin and the Financing of Terrorism: Involvement in illegal financial activities such as the use of money of unknown origin and terrorist financing is to be avoided. This requires suppliers’ financial transactions to be transparent, traceable, and legally compliant.

Data Protection: Our business partners are obliged to ensure the confidentiality of personal and corporate data related to the business and their business partners. This includes protecting customer and employee information, implementing appropriate data protection policies, and taking measures against data breaches. 

Trade Secrets Protection: Our business partners must protect the trade secrets entrusted to them or acquired during their business relationship and avoid unauthorized use of this information

Preventing Conflict of Interest: Business decisions must be objective and avoid any conflict of interest. This requires suppliers not to put their own interests or the interests of close associates, relatives, or friends ahead of the interests of the company. 

Use of Media and Social Media: When sharing information about the company on media and social media, it is crucial to be careful and responsible. Accurate and appropriate information should be shared to prevent the spread of misleading or harmful information and to protect the company’s reputation.

KVKK (Personal Data Protection Authority) Compliance: Compliance with legal requirements for the protection of personal data under the KVKK is mandatory. This requires that data collection, processing, and storage processes are managed in accordance with the law. 

Transparent Reporting and Communication: There should be clear, accurate, and timely reporting on company activities. This ranges from financial reporting to business processes and performance metrics.

Protecting Intellectual Property: Intellectual property rights must be respected and not infringed upon.

Information Sharing: When necessary and appropriate in business relationships, information must be shared in an open and fair manner. This means that information sharing must be carried out in the best interest of both the company and its business partners. 

Transparent Communication: All internal and external communications must be based on transparency and honesty. This requires providing clear and accurate information to all stakeholders.

4.3. Environment

This section details our company’s expectations from our suppliers, customers, business partners and stakeholders regarding environmental sustainability. Our aim is to collaborate to minimize environmental impact and take joint responsibility for a sustainable future.

4.3.1. Resource Use and Waste Management: 

We expect, 

• Impactful Resource Management: Encouraging the effective and efficient use of resources and contributing to the protection of natural resources by preventing waste.
• Waste Reduction Strategies: Developing innovative approaches to reduce waste generation and implementing methods that minimize the amount of waste in production processes.
• Recycle and Reuse: Creating systems for recycling and reuse of waste, contributing to the material cycle to reduce environmental impact.
• Water Use: Implementing practices such as the correct and effective use of water, water-saving devices and technologies, optimizing processes with attention to water use, increasing wastewater treatment processes, and monitoring the water footprint.
• Air Pollution Management: Reducing the use of fossil fuels, providing low-emission transportation vehicles, and implementing chimney systems in line with the manner of production.

4.3.2. Energy Efficiency and Carbon Footprint: 

We expect,

• Energy Efficiency: Reducing energy consumption, increasing energy efficiency, and promoting the use of renewable energy sources.
• Carbon Footprint Management: Implementing carbon emission reduction strategies and monitoring and reporting greenhouse gas emissions.
• Sustainable Energy Use: Reducing fossil fuel dependency and promoting the transition to sustainable and renewable energy sources.
• Climate Change: Prioritizing climate change awareness in procurement and production practices, conducting awareness-raising activities, and accelerating the transition to renewable energy sources.

4.3.3. Sustainable Materials and Production Methods: 

We expect,

• Eco-friendly Materials: Promoting the usage of environmentally friendly, renewable, or recyclable materials.
• Sustainable Production Process: Adopting production techniques and processes that minimize environmental impact and reducing negative impacts on the environment.
• Compliance with Environmental Standards: Increasing efforts to comply with national and international environmental regulations and standards and continuously improving environmental performance.

4.4. Sustainable Supply Chain 

We expect our suppliers, business partners, stakeholders, and customers to establish their own procurement and stakeholder management systems comprehensively and to continuously review and update these systems. We believe that this process will contribute to raising quality and sustainability standards in each link of the supply chain and thus create a more ethical, transparent, and responsible way of doing business for all our stakeholders. We believe that this approach will contribute significantly to the dissemination of sustainable practices in our sector and to the creation of a positive change in all our business processes. 

4.5. Complaint Mechanism and Tracking 

In the event of any uncertainties regarding compliance with our Supplier Code of Conduct or if misconduct is detected, our suppliers, business partners, stakeholders, customers, and other interested parties may use the following communication channels to raise concerns or report wrongdoing:

Complaint and Whistleblowing Hotline: 00902168070248 

E-mail Address: ethics@semtrio.com 

These communication channels have been established to ensure that all parties in our supply chain are heard and issues are addressed fairly. Complaints and whistleblowing can be about anything and may include the following topics: 

• Unethical practices,
• Bribery and corrupt behavior,
• Money laundering of unknown origin,
• Threat,
• Fraud,
• Child labor,
• Repression and harassment,
• Discrimination,
• Inhumane treatment,
• Prevention of freedom of association,
• Wages and working conditions.

5. REPORT MECHANISM PROCESSES 

All complaints and reports will be treated with confidentiality and sensitivity.

We guarantee that whistleblowers will not be retaliated against in any way. All complaints can be handled anonymously, and the identity of the whistleblower will be protected.

We have a system in place to ensure that complaints and whistleblowers are effectively monitored and processed in a timely manner.

Each complaint and whistleblowing will be carefully and diligently examined by experts in their fields, and a fair and impartial evaluation will be made. 

We are committed to a zero-tolerance policy for violations of our Supplier Code of Conduct. 

This process is designed to encourage full compliance by all our stakeholders and to address potential violations quickly and effectively. Any complaints and reports will be handled with due sensitivity and care, and effective action will be taken where appropriate. 

Supplier/Customer Title: 

Supplier/Customer Address: 

Signatory First Name Last Name: 

Signatory Title: 

Date: 

Signature:

Revision Number: 1.0

Date of Revision: 17.08.2023
Date of Preparation: 15.06.2023