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[STRATEGY AND MANAGEMENT]



               ETHICS MANAGEMENT


















               — Our business ethics



               approach based on honesty and



               accountability creates the basis



               for all stakeholder relations of                                                                                    The booklet “Handbook for Borusan Employ-          The Ethics Board may be reached 24/7 by



               Borusan Group. We lead the                                                                                          ees: Business Principles, Business Ethics and      phone or e-mail. The processes of investigat-
                                                                                                                                   Human  Resources  Practices”,  composed  by
                                                                                                                                                                                      ing the notices received from group compa-
                                                                                                                                                                                      nies are conducted by Borusan Holding Audit
                                                                                                                                   Borusan Group Ethics Board, which defines in
               way in the industries we operate                                                                                    detail the business principles concerning topics   Director and Borusan Holding Legal Director;
                                                                                                                                   such as human rights, environment and public
                                                                                                                                                                                      notices conveyed to the Ethics Board by Boru-
               regarding ethics, fair competition                                                                                  activities, the outline for the implementation of   san Group employees or third parties are un-
                                                                                                                                   ethical rules and the rules of conduct regarding
                                                                                                                                                                                      disclosed. The examination and investigation
                                                                                                                                   stakeholder relations, which all employees are
                                                                                                                                                                                      works are conducted by independent experts
               and fight against corruption, and                                                                                   obliged to act accordingly, can be reached on      in secrecy.
                                                                                                                                   our corporate website.

               make maximum effort to raise                                                                                        Besides the responsibility of our employees to     Every year, we provide trainings to all the
                                                                                                                                                                                      white-collar employees working at group com-
                                                                                                                                   comply with the ethics rules, they are expect-
                                                                                                                                                                                      panies, about ethics and risks associated with
               community awareness in these                                                                                        ed to guide relations amongst employees and        corruption, which is an ethics subtopic. In the
                                                                                                                                                                                      reporting period, 170 hours of ethics training
                                                                                                                                   stakeholders according to these principles.
                                                                                                                                   The responsibilities of investigating notices      was provided. Borusan Holding is among the
               issues.  —                                                                                                          received through the Borusan Group Ethical         founding members of the Ethics and Reputa-

                                                                                                                                   Rules Consultation and Information Line, where
                                                                                                                                                                                      tion Society (TEID), which was established with
                                                                                                                                   complaints regarding violations of ethical rules   the aim of enhancing business ethics aware-
                                                                                                                                   are also conveyed, and developing solutions in     ness in Turkey and raising awareness about
                                                                                                                                   relation to these notices belong to the Ethics     this issue both in the business world and the
                                                                                                                                   Board that works under Borusan Holding Inc.        community.
                                                                                                                                   Chairman of the Board of Directors.






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