Ethical Principles Policy

This Code of Ethics Policy sets forth the principles and rules that TIO Logistics Limited Company (hereinafter referred to as “TIO Logistics”) shall follow both within its own organization and in its activities with third parties.

This policy also represents the commitment that all parties aware of their responsibilities under these Ethical Principles shall establish honest and transparent relationships with TIO Logistics’ stakeholders and that TIO Logistics shall fully comply with all applicable international, national, and local laws and regulations in its operations.

1. General Commitment and Purpose

Our ethical principles form the foundation of all our business processes and guide our decision-making mechanisms.

This commitment is indispensable for the reputation and sustainable success of our company.

TIO Logistics undertakes to ensure full compliance with all national and international laws and regulations in all its activities.

Our company adopts an ethical framework aligned with its Quality, Safety, Health, and Environment (QSHE) and Corporate Social Responsibility (CSR) policies. These ethical principles complement and support our QSHE and CSR policies.

All TIO Logistics employees, managers, business partners, and their employees are obliged to act in accordance with these ethical principles.

2. Human Rights and Employee Rights

Protecting the rights of our employees helps us create a workplace environment based on trust and respect. Providing equal opportunities to all employees enables us to build an inclusive corporate culture.

TIO Logistics respects internationally recognized human rights. Child labor and forced labor are strictly prohibited. Discrimination based on race, gender, religion, age, disability, or similar grounds is not permitted.

3. Fair Employment

TIO Logistics is committed to providing all employees with equal opportunities and a safe and respectful working environment.

Recruitment, promotion, compensation, and termination processes are carried out without discrimination; decisions are based solely on merit, performance, and job requirements.

Employees are granted access to the social rights to which they are entitled, and fundamental working conditions such as working hours and rest periods are regulated in compliance with applicable laws.

TIO Logistics supports employee development by offering training and development opportunities and adopts an approach that promotes work-life balance.

4. Freedom of Choice and Association

No employee is compelled to work at TIO Logistics. Each employee has the right to freely choose their employment and to terminate their employment contract in accordance with applicable laws and regulations.

We respect employees’ rights, within the framework of employment contracts and local legislation, to organize, join labor organizations, appoint representatives, and engage in collective bargaining. Internal consultation and representation through appointed representatives are encouraged.

5. Conduct Towards Society

Our employees are the face and reflection of our company. They are expected to maintain a courteous and respectful attitude towards one another, as well as towards our customers and business partners at all times.

6. Personal Data and Information Security

Data security is critical to protecting the rights of both our employees and our customers.

All company and employee-related data are protected in accordance with applicable international data protection and privacy laws. Ensuring the security of personal data and maintaining ethical standards in electronic communications are fundamental principles.

7. Diversity, Equality, and a Harassment-Free Environment

We value individual differences and consider diversity a corporate asset. Combating harassment and discrimination ensures that employees feel safe in the workplace.

TIO Logistics promotes diversity and provides an inclusive working environment. A zero-tolerance policy applies to bullying, sexual harassment, physical or verbal violence, and similar behaviors. Employees have the right to report unethical conduct anonymously.

8. Occupational Health and Safety

Occupational Health and Safety (OHS) practices directly impact the well-being and productivity of our employees. A safe and healthy working environment is provided, and maximum effort is made to prevent potential accidents.

Compliance with the most up-to-date safety regulations is ensured, including the provision of appropriate tools and equipment and the implementation of preventive measures against injuries, illnesses, occupational diseases, and material damage.

9. Environment and Sustainability

TIO Logistics fully complies with environmental legislation and strives to minimize any adverse environmental impacts arising from its activities in order to leave a sustainable environment for future generations. The company supports clean sweeping programs aimed at preventing plastic dust particle pollution.

Subcontractors are encouraged to operate with environmentally friendly, low-emission, and fuel-efficient vehicles. Employees actively contribute to achieving environmental objectives aligned with this purpose.

10. Business Ethics and Integrity

We act in accordance with the principles of transparency and accountability in all our business relationships. When unethical conduct is identified, necessary disciplinary procedures are initiated without delay.

TIO Logistics operates in line with principles of transparency, fair competition, and respect for intellectual property rights. Fraud, misuse of information, and misrepresentation of facts are strictly prohibited.

11. Anti-Corruption, Anti-Bribery, and Gift Policy

Integrity and impartiality are fundamental principles in our business relationships. The acceptance of gifts is limited to ensure that employees’ decision-making processes are not influenced.

Corruption, bribery, embezzlement, and money laundering are strictly prohibited. Symbolic gifts with a maximum value of 200 TL may be accepted. Cash or cash-equivalent gifts may neither be offered nor accepted.

12. Conflict of Interest

Employees are required to prioritize the company’s interests in the performance of their duties. Personal interests must not conflict with the interests of the company.

Employees are obliged to avoid activities that may create a conflict of interest.

13. Implementation, Reporting, and Audit Process

Compliance with ethical principles is supported through regular training and awareness activities.

Audit results are evaluated through feedback mechanisms to ensure continuous improvement.

All employees are required to comply with these ethical principles. Serious violations must be reported to management or designated representatives.

All stakeholders and interested parties may report violations via email at etik@tiolojistik.com.tr and/or through the ethics hotline indicated on the company’s website.

Employees who report violations are protected, and reported non-conformities are investigated and subject to appropriate sanctions where necessary.

14. Acceptance of Consequences

If non-compliance is identified as a result of the audit of our legal obligations, we shall investigate the findings and take the necessary corrective measures.

Where findings confirm violations, TIO Logistics shall accept and bear the legal consequences arising therefrom.

15. Anti-Competitive Practices

TIO Logistics attaches great importance to the protection of fair and free competition in all its activities. We strictly reject anti-competitive practices and do not permit any activities that distort market dynamics, including price fixing, market allocation, restriction of supply, or bid rigging. Our company fully complies with all relevant national and international legislation and adopts ethical business conduct as a fundamental principle.

In this context, we remind our customers and subcontractors that no anti-competitive practices should be involved at any stage of our cooperation. TIO Logistics commits to contributing to the establishment of a sustainable and healthy competitive environment in the sector by acting in accordance with the principles of transparency, integrity, and legal compliance.

Human Resources Policy

Human Resources is a strategic function that encompasses the management and development of employees, who are the most valuable asset of an organization. The Human Resources Policy prepared within this framework establishes the fundamental pillars that support our company’s people-oriented approach, ethical values, and sustainable growth objectives.

This document has been designed to guide all human resources practices with the aim of strengthening our corporate culture, increasing employee satisfaction, and ensuring efficiency in business processes.

The policy section sets forth the fundamental principles, values, and strategic approaches adopted in our human resources management. Issues such as equal opportunity, respect for employee rights, ethical standards of conduct, training, and development are addressed in detail. These principles not only ensure legal compliance but also enhance corporate commitment by enabling employees to feel secure, valued, and motivated in the workplace.

This document serves as an official reference source established to ensure quality, fairness, and continuity in our human resources management. Compliance with this policy by all employees will support both their individual development and the Company’s long-term success. In order to enhance the effectiveness of our human resources practices and ensure continuous improvement, this document will be reviewed and updated regularly.

1. Purpose and Scope

Our Human Resources Policy defines the fundamental principles, values, and implementation guidelines applicable to all employees of the company. This policy covers all human resources processes from recruitment to termination and emphasizes the strategic importance of human capital for the company’s sustainable success.

All employees, managers, and relevant stakeholders fall within the scope of this policy.

2. Fundamental Principles and Values

The fundamental principles adopted in our human resources management are fairness, transparency, trust, respect, and continuous development. Through these principles, we aim to establish a workforce infrastructure built on trust, long-term employment, and career planning.

We respect the rights of all employees and support equal opportunity and diversity. Our corporate values aim to ensure that employees feel secure and valued in the workplace.

3. Equal Opportunity and Prevention of Discrimination

Our company adopts the principle of equal opportunity in recruitment, promotion, training, and all other human resources processes. Discrimination based on race, gender, age, religion, disability, or any other grounds is strictly prohibited.

Providing a fair and impartial approach to all employees is one of the cornerstones of our corporate culture.

4. Employee Rights and Ethical Rules

We respect the fundamental rights and freedoms of our employees and act in accordance with ethical standards. Honesty, confidentiality, mutual respect, and professionalism are essential in the workplace.

All employees are expected to comply with the company’s ethical rules and applicable legal regulations.

5. Recruitment and Placement

Our recruitment processes aim to select competent candidates who align with the company’s needs and corporate values. Objective criteria are used in candidate evaluations, and transparency is ensured throughout the process.

Orientation programs are planned and implemented to ensure that newly hired employees adapt quickly and effectively to their positions. Job descriptions are defined, and the necessary support for development is provided.

6. Training and Development

We organize continuous training and development programs to support the professional and personal development of our employees. Training and Behavioral-Based Safety (BBS) needs are regularly analyzed, and opportunities are provided to enhance employees’ competencies.

By adopting a learning organization culture, our company aims to maximize the potential of its employees.

7. Performance Management

Our performance management system supports employees in achieving their goals and contributing to the company’s strategic objectives. Performance evaluations are conducted at regular intervals based on objective criteria.

Through feedback processes, employee development is encouraged, and achievements are recognized and rewarded.

8. Compensation and Benefits

Our compensation policy is based on fairness, competitiveness, and transparency. To increase employee motivation and strengthen commitment to the Company, we provide various fringe benefits and social opportunities.

Compensation and benefits are reviewed regularly, taking into account market conditions and the company’s financial position.

9. Employee Communication and Participation

Open communication and employee participation are critical to the company’s success. We establish various communication channels through which employees can share their opinions and suggestions.

With a participatory management approach, employees are encouraged to actively contribute to decision-making processes.

10. Occupational Health and Safety

The health and safety of our employees is one of our highest priorities. Full compliance with occupational health and safety legislation is ensured, and risks are regularly assessed.

Necessary measures are taken to provide a safe working environment, including the provision of personal protective equipment (PPE) where required, continuous monitoring of work areas, and ongoing improvement activities.

11. Employee Satisfaction and Motivation

Regular surveys and assessments are conducted to increase employee satisfaction and motivation.

Motivation-enhancing practices are developed by considering employees’ work-life balance. The company prioritizes employee happiness and engagement.

12. Confidentiality and Protection of Personal Data

All personal data of employees are protected in accordance with applicable legislation and company policies.

Necessary technical and administrative measures are implemented to ensure data confidentiality and security. Unauthorized sharing of employees’ personal information is strictly prohibited.

13. Review of the Policy

Our Human Resources Policy is regularly reviewed in line with changes in legislation, sector dynamics, and company needs.

When deemed necessary, the policy is updated and communicated to all employees. Its effectiveness is measured through periodic evaluations.

14. Discipline

All employees may freely submit their requests and complaints in line with their needs and expectations.

A Discipline Procedure, Trusted Person mechanism, and Ethics Committee structure are in place, and all processes are conducted in accordance with the principle of confidentiality.

15. Working Environment

An effective working environment is established by considering social, physical, psychological, and environmental factors while employees perform their duties as defined in their job descriptions. Necessary hardware and software are provided.

Employees are expected to be aware of environmental factors affecting them and to contribute to continuous improvement and development efforts.

16. Employment of Disabled Individuals and Former Convicts

The term “disabled individual” refers to persons certified by an authorized medical board report indicating a minimum 40% loss of bodily function. The term “former convict” refers to persons with a finalized criminal conviction.

Our company operates in compliance with applicable legislation regarding the employment of disabled individuals and former convicts.

In accordance with labor legislation, employers operating in private sector workplaces employing fifty (50) or more employees are required to employ disabled individuals and former convicts at the legally specified rates. The number of employees to be employed under this obligation is calculated based on the total number of employees within the same provincial boundaries.

Accordingly, if the total number of employees exceeds 50, our Company employs disabled individuals and former convicts at the legally required ratios.

In cases where the employment of disabled individuals or former convicts is mandatory under legislation and the required quota is not fulfilled, recruitment for the relevant position is carried out through the Turkiye Employment Agency in compliance with legal requirements.

Integrated Management System Policy

Our Scope;

“Tank container operations; domestic and international transportation of bulk liquid and gas chemicals and bulk food products.”

As TIO Logistics, we are fully aware of the importance of meeting stakeholder needs and expectations, fulfilling our environmental responsibilities, protecting the health and safety of our employees, and maintaining the highest level of service quality.

We are committed to continuously improving the knowledge and competencies of our employees, ensuring their health and safety, maximizing customer satisfaction, enhancing our quality standards, increasing energy efficiency, minimizing environmental impacts, and supporting sustainable development.

This policy has been established to achieve these objectives through an integrated management approach.

1. Our Commitments

To establish measurable objectives and targets within the scope of the Integrated Management System (IMS), monitor them periodically, and ensure the availability of necessary information and resources to achieve them.
To collect, record, and report performance and operational data and inform relevant interested parties.
To identify risks and opportunities and plan the necessary actions.
To ensure compliance with all applicable national and international legal and other requirements related to our services and activities.
To develop projects aimed at the continual improvement of the Integrated Management System.
To periodically review and enhance the suitability and effectiveness of our Integrated Management System.
To support and allocate resources for developing a behavior-based safety culture among TIO Logistics employees and subcontractor personnel across all working areas.
To lead the implementation, monitoring, development, and promotion of this policy and ethical principles together with all employees and subcontractors as our highest priority responsibility.

1.1 Quality

To establish strong and long-term relationships with customers and ensure business continuity.
To evaluate customer needs and expectations and provide appropriate services accordingly.
To allocate necessary resources to meet customer requirements.
To provide cost advantages through multimodal transport solutions, including alternative routes and pricing options.
To evaluate customer feedback promptly and provide effective solutions.
To continuously monitor and improve customer satisfaction.

1.2 Occupational Health and Safety

To eliminate hazards and reduce OHS risks to provide a safe working environment.
To prevent work-related injuries and ill health.
To establish an OHS culture and ensure employee consultation and participation.

1.3 Environment

To prevent pollution at its source and minimize waste generation.
To reduce the environmental impacts of our activities through life-cycle assessment approaches.
To use natural resources efficiently.
To identify activities that generate greenhouse gas emissions and reduce emissions within the scope of climate change initiatives.
To use appropriately equipped cleaning stations and environmentally sound cleaning methods both domestically and internationally.

1.4 Energy

To implement energy-saving measures and efficiency-enhancing improvements across all activities and promote the use of renewable energy sources.
To develop projects aimed at reducing carbon footprint and water footprint.
To prioritize environmentally and energy-efficient technologies in new projects and equipment procurement.
To ensure the design or procurement of energy-efficient products and services.

1.5 Training

To conduct training needs analyses.
To organize training programs for the continuous development of employees’ knowledge and skills.
To establish programs supporting career development and encourage participation in training activities.
To conduct training periodically using diverse and innovative methods.
To measure and evaluate the impact of training on employee performance.

1.6 Social Responsibility – Stakeholder Engagement

To act fairly and equally in human rights matters and remain sensitive to the traditions and cultures of all countries in which we operate nationally and internationally.
To prevent discrimination among employees based on religion, language, belief, sect, race, color, gender, political opinion, age, physical disability, or similar reasons.
To avoid all behaviors contrary to ethical principles and code of conduct and to train employees accordingly.
To maintain transparent, accurate, consistent, and trust-based communication with all stakeholders.

1.7 Alcohol and Drug Policy

To enforce a zero-tolerance policy regarding the use of drugs or alcohol, or being under their influence, during working hours for all employees and personnel acting on behalf of TIO Logistics.
To apply the disciplinary policy in cases of non-compliance.

1.8 Behavior-Based Safety (BBS)

To provide necessary training and accreditation, particularly in behavior-based safety practices.
To identify, monitor, and eliminate unsafe conditions and unsafe human behaviors through defined actions.
To ensure voluntary and active employee participation in BBS practices and foster open communication and a culture of trust.
To implement observation and feedback mechanisms that promote safe behaviors and reduce unsafe acts through positive reinforcement.
To conduct BBS processes in alignment with national and international OHS standards and SQAS requirements.
To regularly monitor, analyze, and continuously improve the effectiveness of BBS practices.
To ensure that personnel conducting observations possess the necessary professional background or required training and competencies.
To maintain confidentiality of observation data and protect employees’ personal rights and privacy.
To support behavioral awareness, proper selection, and complete on-site use of Personal Protective Equipment (PPE) through observation, training, and feedback mechanisms. PPE usage is considered a key indicator of safe behavior and an integral part of BBS processes.

1.9 Security

To ensure the protection of third parties, personnel, customer assets, and information.
To safeguard customer property against intentional damage and theft, and to ensure secure handling and delivery in accordance with final destination requirements and customer expectations.
To conduct Journey Risk Assessments (JRA) addressing environmental, human, and security aspects and implement necessary actions.

1.10 Corporate Social Responsibility

To conduct all TIO Logistics operations through an integrated business model aligned with the Corporate Social Responsibility (CSR) philosophy.
To avoid discrimination among employees, consult them on significant matters, provide flexible working hours and locations where possible, act with integrity, transparency, and proactivity, and share corporate values and ethical principles with interested parties.

1.11 Nonconformity Reporting

To conduct necessary analyses upon identifying any nonconformity, determine root causes, define corrective actions, implement them, share results with relevant parties, and prevent recurrence.

1.12 Information Security

To protect all digital information, including confidential data entrusted to TIO Logistics.
To ensure the confidentiality, integrity, and availability of information.
To restrict access rights in line with job responsibilities and prevent unauthorized access.
To implement secure password management, multi-factor authentication, and periodic password changes.
To apply contractual and technical measures to ensure the security of information shared with subcontractors, suppliers, and business partners.
To implement preventive, detective, and corrective controls against information security breaches and cyberattacks.

Personal Data Protection and Privacy Policy

As TIO Logistics, we attach great importance to the confidentiality of your personal data. This Policy explains how we collect, use, store, and protect the personal data you share with us. Below, you will find information regarding our practices on the protection of personal data.

This Policy has been prepared in accordance with the Turkiye Personal Data Protection Law No. 6698 (“KVKK”) and the relevant legislation.

In matters not expressly regulated herein, the provisions of Law No. 6698 shall apply.

1. Collection and Processing of Personal Data

While you use our services, we may collect personal data such as your name, surname, contact details (telephone number, email address), address, and other necessary information. Such data may be processed for purposes including:

Provision of our logistics services
Customer relationship management
Evaluation of requests and complaints
Fulfillment of legal obligations

Within the scope of the business relationship between our company and the company you are employed by, personal data may be processed—by automatic or non-automatic means, in written and/or wet-signed form or electronically—to the extent permitted by applicable legislation for the following purposes:

Fulfillment of obligations arising from applicable laws, labor and social security legislation
Ensuring and supervising compliance with workplace rules
Ensuring workplace security
Management of occupational health and safety processes
Ensuring the continuity of our Company’s operations
Maintaining existing commercial and legal relationships with business partners, customers, and suppliers
Managing processes before public institutions and authorities such as the Turkiye Employment Agency (ISKUR), the Ministry of Labor and Social Security, and the Social Security Institution.

2. Sharing of Personal Data

Your collected personal data may be shared with third parties solely for the purpose of providing services, within the framework of legal obligations arising from applicable legislation, and after necessary security measures have been taken.
Your personal data may be shared only with:

Suppliers and service providers we cooperate with
Relevant institutions and authorities

Our company may transfer personal data to relevant persons and institutions within the scope of the KVKK and other applicable legislation and for the purposes stated above. Such persons may be those designated by law or determined through contractual arrangements. Employees consent to the sharing of their personal data.

Personal data may be transferred to:

Our direct and indirect shareholders, affiliates, and subsidiaries
Third parties from whom we receive services and/or consultancy
Third parties where sharing is necessary for the continuation of the service relationship
Legally authorized public institutions and private entities
Customers, suppliers, business partners, and service provider companies (such as insurance companies, transportation service providers, travel agencies, technical support companies, etc.)
Lawyers and mediators for the conduct of disputes and legal proceedings
Occupational health and safety service providers, workplace physicians, private and public healthcare institutions, the Social Security Institution, and other relevant public authorities for the fulfillment of our obligations under labor and occupational health and safety legislation

3. Retention of Personal Data

Your personal data will be retained only for the period required by law and necessary for the provision of our services and fulfillment of our legal obligations. Upon expiry of the relevant retention period, your data will be securely deleted, destroyed, or anonymized.

4. Security of Personal Data

The security of your data is of utmost importance to our company. Physical, technical, and administrative security measures are implemented to prevent unauthorized access, loss, or misuse of personal data.

However, since absolute security cannot be guaranteed for data transfers over the internet, we would like to emphasize that appropriate caution should be exercised in such cases.

5. Access to and Correction of Personal Data

Pursuant to Article 7 of the KVKK, you have rights regarding your personal data, including the right to access, update, and request deletion of your data.

In order to exercise your rights, you may submit your request in Turkiye and in writing in accordance with Article 13/1 of Law No. 6698, or via registered electronic mail (KEP), secure electronic signature, mobile signature, or by using the email address previously notified to and registered in our system, to the email address specified in Article 6.

The Company shall conclude your request free of charge as soon as possible and no later than thirty (30) days, depending on the nature of the request. However, if the process requires an additional cost, the fee determined by the Personal Data Protection Board may be charged.

The Company reserves the right to verify your identity before responding.

6. Contact Information

For any questions or requests regarding your personal data, you may contact us at: info@tiolojistik.com.tr

7. Confidentiality Obligation

All commercial secrets of TIO Logistics or its customers learned by the employee, including but not limited to formulas, know-how, ideas, business methods, procedures, computer programs, customer information, financial, technical, commercial, market and production information, whether written or oral, obtained during the commercial relationship, shall be deemed “Confidential Information.”

The Employee:

a) Agrees that the confidential nature of the Confidential Information shall be preserved and that such information shall be used solely within the scope of the commercial relationship, and shall not use it for personal benefit or for the benefit of any third party or for commercial gain;

b) Shall not disclose Confidential Information to any third party other than employees, managers, board members, shareholders, representatives, and professional advisors as regulated under this agreement;

c) Shall not reproduce, copy, distribute, or record in writing any part of the Confidential Information except where necessary within the scope of the commercial relationship; any reproduced or recorded Confidential Information shall remain the property of TIO Logistics;

d) Shall disclose Confidential Information only to employees, managers, board members, shareholders, representatives, or professional advisors who need to know such information for the performance of their duties, provided that such persons undertake to comply with this confidentiality commitment.

Breach of the confidentiality obligation shall result in the obligation to compensate all damages incurred by TIO Logistics, its customers, or business partners, and shall further require payment of a contractual penalty of USD 10,000 to TIO Logistics.

8. Amendments and Entry into Force

This Privacy Policy may be updated from time to time in line with legal requirements and changes within our company. Policy amendments shall become effective upon the entry into force of relevant legislation, upon your written declaration, or upon publication on our website.

Within the scope of this consent and the agreements to which the company is a party, and to the extent permitted by law, employees declare that they have been duly informed and that they give their consent to the recording and sharing of their personal data.