NUH CIMENTO GROUP COMPANIES

BUSINESS ETHICS RULES

Introduction

Ethical Rules of NUH Çimento Group Companies are compatible with Company values ​​and include basic behavioral principles. In summary, the Rules of the company and its employees; Internal and/or external to the company; It covers fundamental behavioral and ethical responsibilities in business and dealings with employees/customers/suppliers, competitors, shareholders, government agencies and the community.

Employees must know, understand, internalize and abide by these rules. Employees are expected to consult their managers and human resources in case of potential violations or violations against themselves or others. In case of disagreement, the Disciplinary Committee is applied. The ”Board of Directors” and ”The Disciplinary Board” act together.

Responsibilities

The principle of honesty is based on all relations between employees, customers, suppliers, partners, shareholders and society regarding group companies.

Legal Responsibilities

  • NUH Group Companies professionally carry out all their activities and processes in line with company policies and strategies, within the framework of relevant laws, regulations and technical standards. In case of potential and/or actual conflict, it provides the explanation of the subject.
  • It acts in accordance with the contracts in all its activities and processes and expects this from all relevant parties and employees.
  • It fulfills its contractual obligations in commercial relations fully and on time.
  • It ensures that all domestic and international activities comply with national and international legislation.
  • It provides accurate and complete information in accordance with the deadlines set by authorized regulatory and supervisory institutions.
  • Irregularity, bribery, false reporting, etc. It certainly does not allow unethical activities such as.
  • It respects all legal rules, moral and social values ​​of the country in which it operates.
  • It does not exhibit attitudes and behaviors that will prevent the unethical behavior and processes of group companies and other legal/real persons from being exposed.

Responsibilities Towards Employees

Business Relationships

  • Listens, respects and evaluates people’s opinions in business relations. He expects this from all his employees and the people he works with. It prevents the formation of an individual and/or mass conflict environment.
  • It does not allow false, misleading and sensational information flow that will adversely affect the working environment and relations.
  • It respects, values ​​and treats with fairness the values, thoughts, opinions and professions of its employees, customers, suppliers, partners, shareholders and society.

Impartiality, Equal Opportunity

  • It provides a working environment free from discrimination, exclusion, terrorization, disrespect, pressure and mobbing. It absolutely does not allow harassment and disturbances against the sexual, social, psychological and physical rights of any employee.

Employee Rights and Development

  • It offers a working environment where fundamental human rights are respected. It treats all individuals, institutions and organizations equally and respectfully, regardless of religion, language, race, gender, culture and opinion.
  • It is believed that the working environment environment is exemplary and the cooperation of different nations creates a more effective business environment, therefore providing a competitive advantage.
  • It meets the personal rights of its employees in a timely, full and fair manner.
  • In line with the Company values ​​of its employees, it cares about both the realization of the Company’s goals and the realization of its own goals.
  • It evaluates the suggestions, talents and experiences of its employees as opportunities for the development of the organization and processes.
  • It supports the establishment and continuity of the balance between business life and private life.
  • It supports the development of talents and competencies of its employees by adding value to themselves and the work they do, and makes the necessary incentives and investments for this.
  • It ensures occupational health and safety in all its processes and develops systems to prevent occupational accidents. It supports the dissemination of HSE (Health-Safety-Environmental) culture throughout the Company.
  • Employees are exposed to alcohol, drugs, etc., which may affect their job performance and/or healthy decision making. They do not work by purchasing, they are not found in the office and factory area.

    Responsibilities to Customers

    Compliance with Commitments

  • It undertakes only the services it can do and the products it can produce to meet customer expectations.

   Product and Service Quality

  • It offers its production quality to its customers in a way that always keeps it superior.
  • Environmental Management System, Quality Management System and Occupational Health and Safety Management System etc., which continue their activities in accordance with TSE standards in product and production processes. employees and is committed to continuous improvement.
  • It follows and implements technological developments that will facilitate human life, support life in better conditions, protect the natural environment, use more efficient energy and less resources, and carry out design and development studies in its products and processes.

Customer Satisfaction

  • It qualifies customer satisfaction as one of its core values ​​and customer focus comes first.
  • In case of any problem in its products and services, it establishes the infrastructure that its customers can easily access and supports it by providing resources.

Responsibilities to Business Partners, Suppliers and Customers

  • Consultant, delegate, intermediary, etc. evaluates business expertise, reliability, impartiality, accuracy and adherence to law as basic criteria in the selection and appointment of individuals.
  • It clearly declares the working conditions of the institutions and organizations and suppliers with which it will have a business relationship and evaluates all offers impartially.
  • It adopts an equal approach to suppliers, customers and business partners in business processes. It encourages its suppliers and customers to prevent discrimination, to attach importance to sustainability and occupational health, to increase the number of female employees, and to adopt an equal pay policy.
  • The principles of giving priority to businesses established by sensitive masses in the supply chain are determined and implemented based on the sector in which the company operates and the product/service to be purchased

Responsibilities to Shareholders

  • It shows maximum effort to comply with the Corporate Governance Principles, explains the reasons for conflicts of interest that may arise due to non-compliance with the principles and the measures taken in areas where compliance is not achieved, in the relevant sections.
  • It aims to be the best in our country in the areas of shareholding rights, public disclosure and transparency, satisfaction of stakeholders, and responsibility towards society and the environment. It is extremely sensitive about the practices required by “Good Governance” and carefully oversees the internalization and implementation of Corporate Governance Principles.
  • The company acts in accordance with the law in the purchase and sale of its shares, evaluates the interests and opinions of the shareholders, does not allow speculation, and maintains its transparency within the framework of the legislation.
  • It focuses on value-added products in a sustainable growth perspective, ensures the continuity of raw materials, realizes environmentally friendly and productivity-enhancing investments, increases logistics power, saves energy, and manages its current investments within the framework of efficient and reasonable profitability.
  • It ensures that the communication with the shareholders is accurate, transparent and timely. It does not provide false or misleading information.

Responsibilities to Competitors

  • It competes within the framework determined by laws, statutes and regulations and within the framework of ethical rules.
  • It does not make a negative statement by declaring the names and managers of its competitors.
  • It does not engage in anti-competitive actions such as sharing the market with its competitors or preventing new competitors.
  • Respects competitors’ patents, copyrights and intellectual property. Avoids anti-competitive behavior, price fixing, or other monopolistic tactics.

Responsibilities to Society and Public Institutions

  • It approaches public institutions and organizations, political parties and non-governmental organizations with equal distance and impartiality in all its activities and processes.
  • All financial information pertaining to operations and management is kept, approved and audited by authorized persons, in full, accurate, complete, timely and in accordance with the relevant acceptance and Laws, When necessary, accurate and complete information is given to company audit institutions and boards and relevant units.
  • It takes care to ensure that all notifications and financial reports it makes to the public and shareholders are accurate, understandable, transparent and timely.
  • It takes care to ensure that all notifications and financial reports it makes to the public and shareholders are accurate, understandable, transparent and timely.
  • It ensures that all updates, notifications and changes regarding the investment instruments traded in the Capital Markets Board (CMB) are notified to the relevant units in accordance with the legislation and within the specified periods.
  • It ensures that the communication between public institutions and organizations and the society is accurate, clear and timely. It does not provide false or misleading information.

Environmental Responsibilities

  • It carries out all its projects and plans, investments and activities with environmental sustainability awareness and creates this culture in its employees.
  • The principle of protecting and developing all environmental values ​​in every field in terms of the company’s fields of activity forms the basis of its sustainability.
  • It takes long-term actions for the development of environmental culture in all its activities.
  • In all its activities, in the fight against climate change, reducing greenhouse gas emissions, increasing energy efficiency, controlling environmental pollution, disposal of hazardous wastes in licensed facilities, researching alternative energy sources and reducing the resources used are the subjects considered and realized.
  • In all its processes, it acts in accordance with the Integrated Management System, which includes the requirements of Quality Management Systems, Occupational Health and Safety Management System and Environmental Management System.
  • It encourages its employees, customers, suppliers and partners to engage in activities that consider the environment in their work.
  • It uses the resources it uses efficiently in all its activities and avoids waste.

Social Responsibilities

  • NUH Group Companies support activities and organizations that are carried out in line with the health, welfare and satisfaction of the society, with a sense of social responsibility.
  • It supports university-industry cooperation for a brighter future. As part of their contribution to education, their children are involved in their students’ personal development.
  • It provides institutional support for the creation of forest areas and the development of natural riches in order to protect nature and provide a healthy environment.
  • Based on its experience in the business world, it supports the sharing of all kinds of information, expectations and solutions for the problems of the sector, on various platforms, and informs the public through the media.

Conflicts of Interest

  • It does not approve of any activity that may lead to a conflict of interest, including, but not limited to, working in a second job, having the means to obtain financial income from rival companies, providing external consultancy services.
  • It does not allow the creation of an environment, influences and activities that may prevent fair decision making. It does not accept gifts of high material value, which may hinder impartiality and affect its decision among the related company and its employees.

Privacy and Information Security Internal Information Security

  • It does not use ethical and illegal ways to access other company and individual information and does not allow its employees to use these methods. Prefers and encourages the use of publicly shared information.
  • It absolutely does not allow the sharing of wages and other earnings information of its employees inside or outside the company.
  • All material, intellectual and electronic assets provided by the company are used within the framework of legal requirements and permitted matters required by the business world.
  • The Company does not allow any transfer or sharing of private information, plans and investments, financial information that has not been disclosed to the public (oral and written) outside the Company in any way. (Including the 3rd Person and Members of the Board of Directors.)
  • It protects all patents, trade secrets, copyrights, trademarks, names and also respects the rights of competitors.
  • Company confidential information, project, etc. owned by an employee leaving the company. It is absolutely not allowed to remove their savings.

Personal Privacy

  • Respects the privacy and proprietary information of all interested parties, customers and employees, job applicants, and protects them in accordance with laws, professional standards and ethical rules.

Corporate Identity

  • In cases where employees are expected to speak on behalf of the Company, they are only required to express their previously disclosed Nuh Çimento Group Companies opinions instead of their personal opinions.