1. Purpose
With this policy text, TİO Logistics' commitment to bribery and corruption and its approach to this issue are clearly stated and the company's image is protected. The code of ethics of the company, which is an integral part of this privacy policy is to inform all of the activities of the company are mutually necessary to prevent bribery and corruption policy in the implementation and maintenance of the necessary training that should be given, also in this area responsibilities, rules and sanctions that will be applied for violation of these rules, we aimed to determine.
2. Scope
Anti-bribery and corruption policy covers not only TIO Logistics, its employees, but also Suppliers, Sub-contractors, all business partners who act on behalf of TIO Logistics or provide services to the company, as well as the private and legal persons to whom the company receives services or provides services.
In this respect;
• All TIO Logistics employees, including board members,
• Companies and their employees who receive support services such as counseling, advocacy or consultancy,
• Foreign Service Maintenance and repair companies and their employees,
• Representatives, distributors, agents, such as TIO Logistics, directly and indirectly on behalf of persons and organizations
While the interests protected by this policy are guaranteed by legal legislation, we, as TIO Logistics, have taken this policy into effect in order to ensure the protection of quality and company principles.
It is important to understand that all the practices and restrictions mentioned in this policy text also apply to the individuals and organizations mentioned above. It should be taken into account that if these individuals and organizations engage in any illegal or unethical behavior, our company may also be adversely affected. Therefore, when determining TIO Logistics employees and business partners, it should be ensured that employees and business partners should also act in accordance with these rules by taking into account the relevant regulations and procedures and the text of this policy.
3. Definitions
Bribery: It means the provision of material or moral benefits to the other party directly or indirectly within the framework of an oral or written agreement to enable a person to perform an action contrary to the requirements of his / her duty or outside of the ordinary course of work by means of doing, not doing, speeding up, slowing down, etc. Benefits that can be considered as bribes can be in many different ways, such as cash Money, gifts, event invitations or tickets, debt, forgiveness, charitable donations.
Corruption: It refers to the abuse of the authority possessed by the reason of its position, directly or indirectly, for personal monetary or spiritual gain.
4. Liabilities and Tasks
Board of Management;
• TIO Lojistik, the Board of Management is responsible for the highest level of Anti-Bribery and Corruption Policy.
• TİO Lojistik, the Board of Management accepts this policy text and provides the necessary environment for its implementation.
• It creates and develops internal control systems in order to prevent bribery and corruption.
• It ensures the establishment of communication channels necessary for reporting conduct contrary to the policy text and takes measures to ensure the privacy and security of the notified person.
• TİO Lojistik ensures that the necessary investigations and investigations are carried out within the framework of its legislation regarding the complaints, notices and allegations reached on the subject.
• In the event of a suspicion that a crime has been committed, a decision is taken on whether or not to notify the public prosecutor after the evaluation is made with the TİO legal advisor.
• It ensures that audits are carried out and corrective measures are taken to ensure compliance with legal regulations, regulations, procedures and policies.
Managers and Employees:
• All employees agree to the policy of anti bribery and corruption and act in accordance with the principles in the policy text.
• Managers ensure that the principles in this policy text are understood, implemented and maintained by the business partners they are responsible for and the employees under their management.
• Employees may not be forced to act contrary to this policy in any circumstances and by anyone.
• All TİO Lojistik Employees are responsible for reporting any conduct or suspected violation of this policy to their managers and/or the following communication channels.
• Managers are obliged to inform the following communication channels of complaints, notices and claims reached to them by the employees under their management.
• If the company’s employees suspect a violation of the policy, they may report the situation directly to the Board of Management or to their administrative supervisor. Administrative chiefs are obliged to inform YK of the situation immediately. YK, in the presence of such a situation, business follows the methods set out in this policy and acts as a follower of the action and takes the necessary actions to ensure its sanction.
5. Policy;
As an indication of TİO Lojistik’s sensitivity to business ethics, it has implemented its anti-bribery and Corruption Policy. As the subject is a legally punishing act in addition to work ethics, employees are expected to be sensitive about it and to be considered as part of personal duties and responsibilities, regardless of their working life.
TİO Lojistik is committed to compliance with the laws and regulations, universal legal rules, ethical and professional principles covered by bribery and corruption in all countries in which it operates and is represented. Under this principle, our company acts with a “zero tolerance” approach against bribery and corruption and is committed to continuing its activities in a fair, honest, legal and ethical manner.
All of TİO Lojistik’s regulations, procedures and other regulations support the proper, fair and honest conduct of activities in accordance with the law, and TİO Lojistik is much more sensitive to the fight against bribery and corruption in order to ensure that the rights of all its stakeholders are protected. The policy of combating corruption and bribery has also been implemented as a requirement of the importance given to this issue.
The material value of the interest subject to bribery and corruption, or whether anything should be done for the other party in return, does not matter. If the value of the interest is too low or the commitment made despite the offer has not yet been fulfilled, it would be against the Anti-Bribery and Corruption Policy.
TİO Lojistik’s legal rights of government agencies, suppliers, customers, employees and other stakeholders are protected. All transaction are recorded in a complete, accurate and fair manner and internal control systems are established to prevent unregistered transactions.
6. Encountered or Suspected of Bribery and Corruption
All TİO Lojistik employees are responsible for reporting to their manager and/or the following communication channels immediately any situations they encounter or suspect in connection with bribery and corruption. The following examples can be given in relation to such cases.
• Offering bribes to you or your colleagues
• Relations of interest and conflicts of interest that you have witnessed or known
• Any irregularities you notice in company records
• Attitudes and behaviors such as favoritism or interest that you encounter in auctions and purchases
• Providing benefits to any customer or supplier in violation of legal and TİO Lojistik regulations
• Any agency or person from within or outside TİO Lojistik forces you or your colleagues to act contrary to TİO Lojistik’s text of this policy
You should notify your administrator and/or the following communication channels when you encounter these or similar situations. In some cases, employees may hesitate to complain, even if they witness such incidents, out of concern that they may be harmed. TIO Lojistik’s legal regulations, ethical rules and TIO Lojistik regulations against the people who report and complain therefore will not suffer harm is guaranteed by the Board of Directors. It is essential that the identities of these people are kept strictly confidential and that they do not suffer any harm due to their complaint or notice -if not intentionally, a crime that can be described as fabricated or slanderous- they make.
7. Sanctions for Contrary Conduct and Attitudes
TIO Logistics’ policy of anti bribery and corruption must be adopted and implemented by the employees as well as the regulations, procedures and instructions are fully implemented in all tasks. It should be noted that in case of violation of the anti-bribery and Anti-Corruption Policy, according to TİO Lojistik regulations, the contract of employment may be faced with sanctions that may lead to its immediate termination without compensation. In addition, the actions intended to be prevented in this policy are defined as crimes within the Turkish Penal Code No. 5237 and include severe sanctions.
Although it is not desirable; in the event that the above mentioned policy is taken out, disciplinary investigation will be carried out by operating our company disciplinary rules first. If a situation is determined contrary to our policy by considering the nature of the action, a criminal notice will be made to the prosecutor's office in order to apply for the criminal responsibility of the person in order to ensure an effective investigation and termination of the employment contract of the employee in accordance with Labor Law No. 4857.
8. Investigation
All department managers have the basic responsibility to investigate all acts suspected of irregularities under the anti bribery and corruption policy.
If, as a result of the investigation, it is determined that the acts of corruption were indeed committed, a report will be made to the director general.
The decision to refer the results of litigation or investigation to the relevant legal units and/or supervisory bodies for the purpose of independent investigation will be made with the legal counsel and the Board of Directors.
9. Confidentiality
Department managers and general managers maintain all information they receive with confidentiality. All employees who suspect any activity that amounts to dishonesty or corruption should have confidence in this privacy and should not be concerned that the information they provide will reveal themselves. In this context, the person receiving the information should not be present at the time of investigation or in interviews, her/hir name should not be used. The results of the investigation will only be shared with those who need to know, otherwise the investigation will not be disclosed. This is important to protect the reputation of people who are suspected but subsequently turned out to be innocent, and to protect the company against a potential public obligation.
10. Revision
This policy reviewed periodically in accordance with the changing circumstances and all changes are announced through notice. The current version of these rules is available on request.
11. Validity
This document, which includes anti-corruption actions, comes into force with the approval of the Board of Directors and the General Manager, Quality Management Representative and Legal Advisor are responsible for the administration, revision, interpretation and implementation of this policy.