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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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