1. OBJECTIVE

This procedure has been developed to protect our employees and stakeholders who report illegal, unethical, or inappropriate activities, any human rights violations, or negative environmental impact behaviors that are not accepted by our organization and international standards, and to establish a follow-up mechanism. Transparency, honesty, and compliance with the law are among our most important principles. Accordingly, we encourage our employees and stakeholders and maintain our zero-tolerance policy

2. SCOPE 

This policy applies to all individuals within SEMTRİO EĞİTİM VE DANIŞMANLIK HİZMETLERİ A.Ş.; senior executives, managers, permanent, temporary, or contractual employees, consultants, interns, and all other persons associated with the company, as well as customers, stakeholders, suppliers, and business partners.

3. WHISTLEBLOWING BOARD, REVIEW AND MONITORING: 

The Whistleblowing Board has the duty to protect the building blocks of transparency and integrity at every stage of the company’s business processes, evaluate and conclude the requests and complaints received from employees or institutions with which the company has business relations within the framework of the confidentiality and anonymous delivery mechanism of individuals and institutions, and protect the petitioners and complainants from negative effects such as retaliation, labeling, and discrimination. This board convenes after receiving petitions and complaints. Decision-makers finalize and announce decisions according to the disciplinary procedure.

This procedure will be reviewed annually / on a case-by-case basis and updated as necessary to ensure that it remains in line with legal regulations, international standards followed, risk analysis, and the needs of the company. All written and verbal notifications will be recorded and kept for a limited period.

4. REPORTING TOOLS

Transparency and ethical behaviors are crucial in our company and partnerships. To facilitate anonymous and secure reporting by our employees and business partners, we provide a variety of reporting tools. We hold monthly business development meetings for employees to voice any violations, concerns, or suggestions they may have or may have about ethical work practices, labor and human rights, and environmental impacts. We have a system where our employees can express their requests and complaints in writing, remain anonymous while doing so, and view and rate all requests and complaints online. Every month, in meetings attended by senior management and decision-making mechanisms, we make evaluations and integrate all ideas into business development processes. We also have an active ‘open door policy’ to ensure that any issue can be shared directly with management. These mechanisms exist so that our employees can make their voices heard and contribute to solving potential problems. We have an Ethics Hotline where suppliers, employees, and business partners can report potential violations at any level of the business relationship. Each report will be treated with the utmost confidentiality and seriousness, and appropriate sanctions will be taken. Additionally, our Ethics Hotline that you can reach if you detect unethical behavior from any of our employees:

Complaint and Whistleblowing Hotline: 0090 216 807 02 48 

E-mail Address: ethics@semtrio.com

These communication channels have been established to ensure that the voices of all parties in our supply chain are heard and issues are addressed fairly. Complaints and reports can be about any topic.

5. IMPLEMENTATION 

The Whistleblowing Board and the Disciplinary Board oversee the stages after receiving the complaint of behaviors contrary to the corporate principles or laws of Semtrio Eğitim ve Danışmanlık Hizmetleri A.Ş. Investigations are carried out within the framework of confidentiality and sensitivity. We pledge that no retaliation, discrimination, or labeling will be made against the person or organization that made the report.

Whistleblowing Topics:

• Unethical practices,
• Bribery and corruption,
• Money flows of unknown origin & money laundering for laundering proceeds of crime,
• Conflict of interest,
• Personal data breach,
• Information security breach,
• Anti-competitive practice,
• Fraud,
• Threat,
• Forgery,
• Child labor,
• Repression and harassment,
• Discrimination,
• Inhuman/abusive treatment,
• Human trafficking,
• Prevention of freedom of association,
• Wages and working conditions,
• Occupational health and safety, precautions, risks and emergencies, employee/stakeholder concerns

6. RESEARCH PROCESS

This process includes gathering concrete evidence to determine the truth and scope of the incident (date, time, nature, quantity, frequency of occurrence, location, measures taken, persons aware of the matter, witnesses, method of communicating the matter as a complaint, whether higher-ups were aware of the communication), hearing witnesses and conducting the necessary analysis by the Disciplinary Board and Whistleblowing Board.

The research process is conducted in accordance with our company’s corporate policies, ethical standards, and legal requirements. Each step is meticulously recorded, and the transparency and objectivity of the process are monitored. In particular, if criminal offenses or serious violations that jeopardize public safety are detected during the investigation process, the matter is handed over to law enforcement authorities when necessary, thus ensuring that legal obligations are fulfilled.

7. FINALIZATION

Upon completion of the investigation process, the Whistleblowing Board, depending on the subject matter involved in the process (Labor and Human Rights Committee, Ethics Board, Disciplinary Board, etc.), evaluates and comprehensively analyzes the findings and writes a detailed report. This report is first presented to the relevant parties and management in internal communication, and corrective and preventive actions are recommended when deemed necessary. The entire process is carried out from an objective perspective. The Board is responsible for ensuring that each investigation is finalized within the framework of our company’s high standards and professional ethics.

The finalization phase is critical, where decisions and actions taken are designed to prevent similar violations from recurring, strengthen company policies, and improve company culture. The finalization phase is also an indicator that the investigation was conducted in accordance with ethical and legal standards. Meticulous management of this process is vital to protect the company’s reputation and build trust among employees.

8. COMMUNICATION OF RESULTS 

The results of the investigation are announced to the relevant parties (the whistleblower or the organization) and, if necessary, to all internal mechanisms within the framework of company policies and legal regulations, depending on the nature of the incident (a situation that concerns all employees, etc.). While this communication is carried out in line with the principles of transparency and openness, at the same time, in some incidents, confidentiality and protection of sensitive information are important and are considered high importance by our organization. This process contributes to the prevention of similar situations by increasing trust and transparency within the company. Within the scope of the commitment to protect personal data, it is unacceptable for the whistleblower or the organization to be subjected to any discrimination and retaliation, and no personal data will be shared that may lead to this result.

9. RAISING AWARENESS

Regular training and information campaigns are organized to increase the effectiveness and awareness of the whistleblowing policy. These activities ensure that employees understand their rights, responsibilities, and whistleblowing mechanisms. It also helps prevent potential violations by emphasizing the importance of ethical behavior and transparency in the workplace.

Semtrio encourages not only its own employees but also its suppliers, customers, and business partners to raise awareness about behaviors and rights that may lead to whistleblowing and to strengthen the corporate culture. In documents such as the Supplier Code of Conduct, Semtrio explains in detail its expectations from its suppliers and corrects behaviors and reminds them that the complaint mechanism is actively functioning in case of problems in compliance with these rules.

10. DOCUMENTATION

All reports and investigation processes are documented in detail. These records serve both as evidence that the process was managed fairly and thoroughly and as a source of reference against similar incidents in the future. Documentation is stored in accordance with legal requirements and data protection standards. The Board is committed to maintaining the utmost confidentiality of the whistleblower’s identity and all information related to the whistleblowing. This commitment to confidentiality ensures both the protection of whistleblowers and the conduct of a fair investigation process. Confidentiality principles are strictly enforced throughout the entire process, and serious sanctions may be imposed for breaches.

Revision Number: 1.3
Date of Revision: 17.08.2023
Date of Preparation: 15.06.2023