Code of Conduct and Business Principles

Purpose and Scope

Ethics, in its simplest sense, examines universally accepted value judgments that have general validity in human relationships.  Business ethics encompasses a set of principles developed to guide behavior in the business world.  
The fundamental values and principles of Aydem Energy guide our business ethics rules and constitute our expectations, standards and ethical practices that form the basis of all our business relationships and transactions. 

Aydem Energy Code of Ethics and Business Principles define the rules that “Aydem Energy Anonim Şirketi and all its affiliates” (Aydem Energy) and all third parties and employees acting on their behalf must comply with, employee rights, as well as company ethical valuation and basic principles.

Our Responsibilities as an Employee

Honesty and integrity of our employees are necessary to maintain our reputation, reliability and successes that we acquired by means of role modelling of our leaders. Any behavior that is unethical or incompatible with our business principles is never acceptable or these behaviors cannot be tolerated. It is the duty of every employee to maintain the reputation and success of Aydem Energy.

Each employee must work at the highest professional level in order to meet internal and external customer needs within the scope of his/her responsibility. In addition, employees must work efficiently and contribute to achieve their own goals, the goals of the department and the company, and to meet customer requirements.  
Especially each of us;

• in carrying out our duties, we must act within the framework of fundamental moral and human values and corporate strategies,
• we must act in the framework of honesty and trustworthiness, establish and maintain equal relationships between people, cooperate with other employees for the common purposes and use company assets and resources effectively, efficiently and respectfully,
• we must demonstrate proper conduct and work ethics in accordance with our “Code of Ethics and Business Principles” announced throughout the Corporation; read, understand and comply with all of our corporate principles,
• in fulfilling the duties assigned to us, we must comply with all laws, principles and statutory rules and orders issued by the relevant regulators (Energy Market Regulatory Board, Capital Markets Board, etc.) and professional institutions and organizations of which Aydem Energy is a member,
• we must avoid unfair competition in all transactions and relations with other financial institutions within the framework of honest competition principles, 
• we must remember that being open, complete and accurate to all our stakeholders is part of our identity and reliability, and we must always act in a manner that increases the reputation of Aydem Energy. 

As an employee, each of us is obliged to act in common sense and put in effort as necessary while performing our duties, to take into account the principles of profitability and efficiency and to avoid any actions or transactions that may harm the corporation. We should not forget that behaviors that violate or exceed our “Code of Ethics and Business Principles”, which is regarded as a guarantee of the reputation of our corporation, may lead to ethical review or disciplinary investigation.

Our company expects all of our executives and employees to make judgements in accordance with our “Code of Ethics and Business Principles” while conducting their business. It is important for our executives and all employees to apply these rules frequently and to confirm frequently that they are proceeding on the proper way in accordance with “Code of Ethics and Principles of Work” guide and the purposes of its content and to perform their duties in the most effective and correct manner in line with the corporate objectives.

As a corporation, we recognize that the rules set out in this guide are not fully answered for every question and every situation. In such cases, or if you have any questions or concerns regarding our “Code of Ethics and Business Principles”, you may contact the Code of Ethics Advisor and Human Resources Management.  
The communication channel established to report your questions about our “Code of Ethics and Business Principles” and any violation of our “Code of Ethics and Business Principles” or suspicious situations that may reduce our reputation is as follows:

e-mail :  etik@aydemenerji.com
Telephone :  0 (850) 575 0 575 
Mail delivery  : Adalet Mahallesi Hasan Gönüllü Bulvarı No: 15/1 Merkezefendi / Denizli  (To Ethics Committee)

Confidentiality

Ensuring confidentiality within the corporation
Our employees;
Every employee is obliged to comply with the details specified in the Aydem Energy Information Security Policy and related legislation on information security.

• It is strictly forbidden to use the personal and financial information of customers, suppliers or an employee for unauthorized/out of business purposes (except the disclosure of information and documents required by authorized persons or institutions specified in the law and other legal regulations).
• They may not share the information and documents that they have learned for their work with unauthorized persons and authorities inside and outside the corporation for whatever purpose, and cannot use them for speculative purposes (directly or through a third party).  
• They know that the projects, technical infrastructure, regulations, etc. that they have developed due to their duties are the property of Aydem Energy; they cannot take these and similar materials out of the company without written approval of the highest level manager of the Company. 
• They do not disclose their personal rights, which should only be acknowledged by them, to other internal and external persons.
• They avoid any criticism about the general policies of Aydem Energy that will damage the Company's reputation.
• Apart from their duties, they cannot discuss matters related to their duties and do not cause a situation that may lead to any speculation and negative assessment. 
• In the event that the employee leaves his/her job in the company for any reason, the responsibility of protecting the personal and financial information of the customers remains permanent. It is forbidden to take confidential information outside the corporation, to share it with third parties, or to use such information for personal affairs outside the corporation. 

Protection of Customers' Personal Information 

The compliance of our employees with the standards of professional conduct that ensures the confidentiality of relationships and information between the corporation and its customers is crucial for Aydem Energy’s reliability and reputation. Discussing confidential information about customers or transactions outside of normal business activities and in public areas that may be heard by third parties or mentioning these subjects may cause violation of this confidentiality.

Personal information accessed by our employees for business purposes should be used in accordance with the Personal Data Protection Law (KVKK) and the legislation supporting this law, company policies and procedures.

The use of information arising from their duties or in-house authorities is limited to the situations that are absolutely necessary for Aydem Energy’s legitimate and appropriate business objectives.

Consumption, address, identity information of eligible consumers should never be shared in the interest of other retail/wholesale electricity companies.

In addition, information about how our daily business works (such as our strategic plans and products) and non-public information about customers should be used carefully and meticulously. Even the slightest implication in this respect may cause misunderstandings.

The obligation of Aydem Energy to protect the confidentiality of the information shall also continue in case of resigning from work for any reason.  

Information on Company Ownership

Non-public information, transactions, computer software, technical information, materials, records, files, documents, programs, reports, reviews, data, customer lists, trade secrets and all other information about Company customers and other third parties are the property of Aydem Energy and cannot be used except for work.

Our employees cannot disclose this information to any third party. Under no circumstances, this information shall not be allowed to be known by any competitor or any third party or disclosed during or after the service.

The equipment and goods allocated to the employees by the Company due to their duties are not considered as personal belongings. In addition, the Company reserves the right to audit the user accounts of employees and electronic means of communication such as e-mail, telephone, computer systems and other electronic records assigned to them for business, based on existing laws.

Information Storage

It is our employees' responsibility to be aware of all policies related to the safe management, distribution, transfer, storage or disposal of information. All our employees are obliged to act in accordance with the provisions of the “Information Security Policy” published/to be published by the corporation, except for the issues stated below.

As an employee of Aydem Energy, we are expected to follow these basic policies:
Restricting Access to Confidential Information

• All computer access must be limited to the information required to perform daily tasks. If there is a need to share information with people outside the company, this issue should be questioned in detail and if necessary, the situation should be discussed with Information Security Management and the relevant Code of Ethics Advisor.  
• When sharing information with authorized persons, the necessary information should be provided at the required level. 
• Confidential information should be stored only within the reach and access of authorized persons. When not in active use, documents containing confidential information should be stored securely in a drawer or cabinet, and should not be left in fax machines, printers, or other unsafe locations. 
• Envelopes with the label of “Personal” should be used when distributing such information within the corporation.

Protecting Information in Computer Hardware

• Laptops and other portable devices are highly vulnerable to theft. Such portable devices (computer, tablet, cordless phone, mobile phone, etc.) should not be left in unsafe places. Information Security Management and Human Resources Management should be informed as soon as possible if the device under employee’s liability is lost or stolen. 
• Our employees must lock their computers or log out before leaving their computers.
• User identifications or passwords are private and should not be shared with anyone. Our employee may be held responsible for all use of the user identification or password, including any unauthorized use, and for any damages to the corporation that may arise from any misconduct. In cases where the user identification or password is suspected of being compromised, passwords should be changed and Information Security Management should be contacted. 
• The configuration of the computer's anti-virus program provided by the company cannot be changed.  It is our employee's responsibility to protect the computer allocated by the company from computer viruses that are sent from outside the company on behalf of employee and that will reveal company information. 

Internal and External Relations of the Company

Relations with Government and Public Institutions

The Company's relations with public administration, political organizations, trade unions and other organizations; must be based on the principles of integrity, honesty, equality and independence of the highest level.

Relations with Customers, Suppliers and Other External Organizations

Our employees act in accordance with the principle of integrity in their relations with customers, shareholders, affiliates and other companies while representing the Company.

As Aydem Energy, our main objective is to meet the needs of customers. Customer satisfaction determines the success or failure of our corporation and therefore; our customers are the most important part of our business. In the Company, customer relations management is based on the principles of professionalism, courtesy and more importantly dignity and reliability, as ensuring the customer satisfaction is the best advertising tool we can perform. In customer relations, honesty, equality and compliance with laws should be kept at the highest level.

Employees must provide full and clear information to customers about the products and services of the Company. Employees are not entitled to provide false information in order to make higher profits. Our customers are clearly informed about the rights and obligations on their transactions related to Aydem Energy and the benefits and risks of the products and services offered to them. Therefore, our employees have the responsibility to have the knowledge both on Aydem Energy and on the services and products provided by the Group Companies.

Sales or communication techniques that are incompatible with professional code of ethics, give wrong or incomplete information to the customer about the product or service and make efforts to force the customer in the decision process cannot be used.
In addition to taking into account the company's interests in the activities carried out within the free market economy, in general; employees avoid acts constituting unfair competition within the framework of the principles of continuous trust in the energy sector, making efforts for the development of the sector, observing common interests, and do not express opinions or comments positively or negatively on rival companies and their products and services during their duties.

Relations with suppliers are also based on the rules mentioned above.

Confidentiality requirements should be clearly guaranteed by a contract when dealing with persons or organizations providing counseling services. However, the temporary employment as a consultant of the personnel whose assignment is terminated in the company is subject to the proposal of the relevant business unit manager, the evaluation of the Human Resources Director and the approval of the CEO.

Any Aydem Energy employee shall not make a real or visible commitment on behalf of Aydem Energy formally or in an informal way without authorization in accordance with the approved procedures and does not work with those who harm public morality and harm the environment and public health.

All Company employees should refrain from any activity, practice or action that would violate competition law, in particular abuse of dominant position. The relevant rules are set out in the Competition Law Guidelines.

Media Relations

Our employees should avoid situations that may lead to any speculation, negative evaluation regarding company in the relations of Aydem Energy with the press, and practices and behaviors that may harm the trust, reputation and stability of our corporation or sector or create unfair competition.

In public and in areas where listeners think we are speaking on behalf of the Company, we express not our own opinions, only those of our Company.

Press relations related to the entire Aydem Energy are carried out by the Corporate Communication Directorate. All external relations are maintained within the procedures determined by the company. All requests from the written and verbal media, requests for interviews and all questions should be forwarded immediately to the Corporate Communication Managements of the Aydem Energy.

Priority approval of the Corporate Communications Directorate should be obtained with respect to all contact information to be provided to third parties. Only authorized persons can communicate about the Company and its policies, practices and procedures.

In social networking sites, blogs, dictionaries, forums, and e-mail groups, we avoid expressions that may give the impression that Aydem Energy is represented by third parties.

In addition, the Aydem Energy Digital and Social Media Principles Document, which is published to represent the corporate structure through social media, is essential.

Conflicts of Interest

Aydem Energy does not prevent its employees from engaging in external activities which will not cause their employees to neglect their internal responsibilities, will not restrict their actions in accordance with the interests of the company and which are in compliance with the “Code of Ethics and Business Principles” announced. However, our employees involved in such activities should avoid possible or actual situations that conflict with the Company and their interests.

“Conflict of Interest” occurs when the personal interest of an employee and the Company's interest affect/prevent each other. For example, the responsibilities or obligations of an employee in a situation of self-interest outside the corporation or in his/her private life may make it difficult for him/her to fulfill his/her responsibilities and duties in the Company in an objective/neutral and effective manner. Conflicts of interest may also arise from the personal benefit of one of our employee's family members through his/her position in the Company.

Any transaction or relationship that may create any conflict of interest should be reported to the related Code of Ethics Advisor.

In order to prevent potential conflicts of interest, our employees;

• Refrain from giving rise to situations of conflict of interest or impression in favor of themselves or their relatives, and do not take part in the decision process in matters concerning their or their relatives' interests. 
• Do not enter into any personal financial relationship with customers and suppliers, nor do they gain personal interest through business relationships.
• Do not allow gifts or offers of interest that may affect their decisions and consent or create a conflict of interest. 
• Use the company's assets and resources efficiently only for the corporation’s interest and benefit.     
• Use their time and efforts for the corporation, do not take any other responsibility that may create a conflict of interest and do not work with any other natural or legal person outside the company.  
• In their relations with public institutions and organizations, they act in accordance with the principles of honesty and transparency and maintain the distance and impartial relationship.  
• Protect corporate and customer secrets, and do not take out information providing competitive advantage and corporate-specific information.  
• Do not use the information they have obtained due to their duties in a way that leads to unfair gain.

Corporate Opportunities

Our employees at all levels are required to act in common sense and put in effort as necessary while performing their duties, to take into account the principles of profitability and efficiency and to refrain from any action or operation that could harm the company. Our employees are obliged to use these legal business opportunities whenever an opportunity arises in favor of the company.

Employees may not take decisions or engage in activities that conflict with the interests of the Company or that are incompatible with the responsibilities of the employees. If potential conflict arises, the employee must immediately report the situation to the Code of Ethics Advisor to which he or she is attached.

Our employees; should refrain from not exploiting any opportunity to the benefit of Aydem Energy, which has been reached by using the goods or information belonging to the Aydem Energy or obtained as a result of their position in the company, or preventing other employees from doing so because they are contrary to their own interests.

Prohibition of Borrowing

Our employees should not borrow money, utilize any benefit or enter into a bail relationship with customers, third parties during performing their duties or in connection with their duties under any circumstances.

Our employees should manage their private and financial affairs in a responsible manner and should not bear the debt burden that they cannot pay. Our employees should demonstrate a balanced and harmonious attitude both in their professional lives and their personal financial situation. 
It is forbidden to enter into a debit-credit relationship between subordinate and senior employees and for employees with customers, suppliers and contractors.

Bribery

Bribery is a direct or indirect payment offer or benefit offer to our employees in order to gain illegal benefits and influence decisions and practices. This can occur in many ways, such as payment in cash or non-cash, giving valuable gifts, offering an advantage to the employee for personal benefit, etc.

When our employees are offered with bribery by any person, company or institution, this situation should be reported immediately by our employees to the relevant Code of Ethics Advisor.

Political Activities

Company employees should not be members of political entities using the company’s name while performing their duties. On the other hand, in their personal memberships, they are obliged to avoid any activities that may harm the Company's interests, image and adversely affect working hours.

None of our employees may be involved in political resource management or campaign activities at work or use the company for such activities.

Political Donations

No donations (in cash or any other form) may be made on behalf of Aydem Energy to political parties, political organizations, representatives and candidates of such groups for the benefit of the company directly or indirectly. Our employees should avoid situations that could mean financial or moral support to political parties on behalf of the Aydem Energy.

Acceptance of Gift

It is of utmost importance that the gifts sent to our employees for their duties do not arouse any suspicion about the impartiality of our corporate judgments and decisions in the presence of third parties. Prevention of improper relations with third parties that would undermine the reputation of Aydem Energy is possible with the existence of an institutional approach and application in the acceptance of gift. Therefore, our employees are required to act commonly in accordance with the following rules regarding gift admission.

Our employees cannot request and accept goods/services that is not of a symbolic value (corresponding to 100 USD) or cash, checks, etc. regardless of the value for any transaction or business. 

It is not important that one does not directly benefit from this valuable item. Anything valuable cannot also be acceptable on behalf of a third person or party. 

Gifts, entertainment or other presents that may affect or intended to influence the preferences and decisions of our Company shall not be accepted and such requests shall not be made. 

Any gift that does not comply with the above-mentioned rules must be returned to the sender person or institution by the addressee employee by giving information to the relevant manager. In case the appropriateness of the gift cannot be decided, written approval must be obtained from the relevant Code of Ethics Advisor. 
In cases where the return of a gift with a value of more than 100 USD is decided to be impractical or it is decided that it may have an undesirable outcome in terms of the business relationship, acceptance and use of the aforesaid gift may only be accepted with the written approval of the Code of Ethics Advisor. In such cases, the gift should be accepted and reported to the Internal Audit and Control Directorate at the same time (e.g. within 24 hours). 

Each gift valued at USD 100 or more must be recorded on the basis of Management and the reports made on acceptance of gift should be kept by the Managers to be submitted to the Code of Ethics Advisor when necessary.

In addition, in order to prevent the resubmission of similar gifts from the same institution in the future, the principles and practices of our Company in this regard can be explained to the sender institution or person with a letter of thanks. 

All our employees are responsible for following the procedures mentioned above and informing the Code of Ethics Advisor and Human Resources Management on the issue if they think or witness any violation of this procedure. 

Giving Gifts and Donation

Gifts can be given to customers, business partners or supplier representatives on behalf of the Company within the framework of maintaining the business relationship. Gifts, regardless of their value, should be of a nature that does not affect honesty and decisions to be taken in business relationships. 

The process should be in accordance with the principles and general practices determined by the management of Aydem Energy and should not damage the reputation of the company. The principles applicable to the acceptance of gifts, invitations and donations shall also apply to the giving of these, and USD 100 limit shall be applied for such transactions. 

Acceptance of Events Sponsored by 3. Parties or Events of which Expenses are Covered by 3. Parties 

Our employees should not accept the offer of entertainment, free education, seminars, accommodation, travel, meals, etc. which aim to influence their decisions in their work. 

However, the Company acknowledges that in certain circumstances, rejecting the above-mentioned types of offers may disrupt customer relations. Therefore, offers of participation for free conferences, introductory meetings, training, etc. from third parties or our customers or possible customers may only be accepted with the written approval of the highest level manager of the relevant function and the relevant Code of Ethics Advisor. 

Transactions

Accuracy of Records

Integrity, accuracy and reliability in all kinds of records, documents and financial statements issued on behalf of Aydem Energy are of great importance for the continuation and future of Aydem Energy’s success. For this reason, our employees are responsible for ensuring the accuracy and legal conformity of the records, documents and instruments in all transactions carried out on behalf of Aydem Energy.  

In addition to accounting and auditing records; time records, credit documents, telephone records, transaction records and all other records that are part of our daily workflow are covered by the documents in question. All records should reflect the transactions performed accurately and according to time; in case of errors, errors should be corrected immediately.  

In case of detection of any deception, alteration and/or negligence within the general activities of the company, the Code of Ethics Advisor and Human Resources Management or the relevant department of the company should be informed regarding the situation immediately. 

Employee Stock Transactions - Insider Trading 

Within the framework of the principles of protecting the company's interest with duty of loyalty, it is possible that the company has some expectations from its employees. Within the scope of these expectations of us; 

It is possible for the employees to carry out investment transactions with the shares of Aydem Energy on the stock exchange under the conditions specified in the regulations of the Capital Markets Board. Employees, however, know that it is insider trading trying to obtain any benefit, by using any kind of confidential information of the Aydem Energy or by giving it to third parties, including the purchase and sale of shares directly or indirectly from stock exchanges and these behaviors are criminalized by law. The internal procedures established to implement the regulations of the Capital Markets Board are applied with precision. Employees listed in the “Insiders” list are expected to be in full compliance with the relevant legislation, company policies and procedures.

In accordance with the “Principles Regarding the Sale Methods of Capital Market Instruments in Public Offering” with Serial: VIII, No: 22 of the Capital Markets Board, Additional Article: 1 “Prohibition of Transaction in Public Offering”: “In the sale of capital market instruments through public offering; the issuers that are issuing the capital market instruments and offering to the public and the chairman and members, statutory auditors, managing directors, general manager and deputy director generals and other personnel who may have information due to their duties, their spouses and their first degree blood and physical relatives of the intermediary institutions that mediate the public offering cannot directly or indirectly purchase the capital market instruments in question.”

Employees of Aydem Energy, except for the persons mentioned in the aforementioned circular, may participate in public offering transactions made by companies within Aydem Energy and other intermediary institutions. 

Company Resources

Using of Assets and Resources of Company

Any goods, assets, equipment, vehicles, computers, computer programs, etc. owned by the Company and provided for the employee to carry out the daily business duties shall not be used by any employee for personal benefit or for the benefit of any other person.

Phones belonging to Company, personal computers, photocopy and fax machines, supplies, postal service, e-mail, notice boards and meeting rooms are mainly for company use. The use of specified resources or other company resources for personal purposes may disrupt the flow of information, which is very important.

Company phone and company address, e-mail, interior communication and message system should not be used for personal correspondences and interviews. Utmost care should be taken to keep private phone calls in short time. 

We take into consideration the interests of the corporation in the use of resources on behalf of Aydem Energy Companies; we show sensitivity in protecting company assets. We avoid to lose, damage, misuse and waste of group assets. We do not use company assets and opportunities outside of the company's business without company interest, regardless of being under any name and on behalf or benefit of any person. In cases of public interest or obligation, the approval of the General Manager of the relevant business unit is sought.  

Using Technology

The Internet and Intranet system of Aydem Energy is for transactions, communications and researches related to work. It may not be used for the purposes other than those purposes (watching series/movies etc.) and/or obscene, pornographic and terror purposes. In addition, unlicensed software should not be installed to company computers and used by employees on company computers. Any messages with harassment, threatening content or that would damage the reputation of the corporation shall not be sent with mobile devices of the company under no circumstances. 

Assignment Out of Company

Employees shall not engage in activities that require them to be directly or indirectly regarded as merchants or tradesmen (regarded as “Commercial Enterprise” or “Tradesman Business”), shall not serve as a board member or auditor in companies other than Aydem Energy companies without the written approval of their top manager, may not work paid or unpaid in any commercial work of real or legal entities without the written approval. 

Employees may receive offers to participate in out-of-company activities as either paid or unpaid speaker or consultant with their experiences gained throughout their working life. Such opportunities should be evaluated by the senior manager of the relevant business unit and the Director of Corporate Communications to determine whether there is any conflict between personal and corporate interests. 

Business Communication and Records 

Any written or verbal communication should be done in a professional manner and in accordance with our code of ethics. What we say, write and do should clearly reflect the ethical values and expectations of Aydem Energy and indicate the existence of healthy personal judgement. Exaggeration, misleading, grandiloquent language, too short expressions, legal speculation, insulting words and attitudes towards people, companies and their products and services should always be avoided. 

Everything that employees say, write and do should be aimed at maintaining and reflecting the honesty and respectability of Aydem Energy. This policy applies to all types of communication, including voicemails, emails, official notes and reports. 

E-mail

E-mail is an important interior and exterior communication method. E-mails are records that can only be disclosed if required by legal processes or otherwise needs to be strictly confidential. Any e-mail that does not comply with our ethical standards should not be written or sent in any way whatsoever. 

All e-mails should be compiled by considering that they may be accepted as legal records and written in a professional manner. The transmission of any message should be in accordance with all policies and be protected against unauthorized access. 

The basic rules to be used during using e-mail are as below; 

• E-mail is used when the work requires it.
• While preparing the e-mail, it should be taken into consideration that it is a document that can be seen as a written record, therefore respectful, clear, honest and precise statements should be used. Exaggerated, frivolous language or slang expressions and humiliating words should not be used in e-mail content. 
• Response messages should contain sufficient information to avoid misunderstanding. Communication by e-mail must comply with our ethical standards and policies, nature and purpose of the ethical standards, and each message should be carefully reviewed before it is sent. 
• Our information protection and security standards also apply to e-mail communication. Because e-mail messages are sent outside the Company through public networks such as the Internet and may stop or be misdirected in the meantime. Therefore, care must be taken to ensure that it does not contain any information that could be used in order to harm the company, its customers, employees or any of its shareholders. 
• If confidential information needs to be transmitted via Internet, it must be sent using secure (encrypted) e-mail facility. Business related “Top Secret Information” should not be sent out of the company via e-mail. 
• To reduce the risk of disclosing customer information, if a customer sends an e-mail containing personal information, this information should be deleted from the e-mail reply. 

E-mail facilities should not be used for the below list; 

• To forward or store messages that may be perceived as offensive, insulting or hostile, 
• To forward or store virus alerts or prank messages (Information Security Management should be informed about these warnings), 
• To engage in any communication or activity that could harm Aydem Energy or any of its customers and shareholders,
• To forward chain messages to others, including protests, help or expressions that abuse human emotions (the ones who send such messages should be warned and Code of Ethics Advisor should be informed that there is chain message in the system), 

To forward messages that are not business-related, which may adversely affect the system capacity of attached files containing entertainment games, audio and video, 

To chat through messaging programs during working hours; e-mail and messaging becoming negligence of work. 

The Monitoring of E-Mail and Other Systems Usage of Employe

Aydem Energy reserves the right to monitor whether e-mail, computer files or systems allocated to its employees are used for their intended purpose. 

The Company has the right to audit all communications via e-mail, to intervene and read as necessary. All kinds of documents, contract theft, unauthorized photographing, questions asked to employees with the intention of leaking information are considered as security violation. The personnel accept this enforcement in advance. If the data/information security violation event is executed by the Company employee; disciplinary provisions shall apply to the related person and the offender responsible for the negligence incident. If it is executed by a person or institution outside the Company; in cases of necessary, legal proceedings will be pursued. 

Within the scope of ethical review and disciplinary investigations carried out; if deemed necessary, the only unit authorized to examine the records of devices and software provided for the usage of the relevant personnel by the Company (notebook, external data storage device, mobile phone, tablet, e-mail, Skype, SMS, etc.) is the Internal Audit and Control Directorate. The relevant records may be subject to review by the Internal Audit and Control Directorate upon written request from the Information Technologies Directorate. This authority cannot be transferred to another unit on no account and the data cannot be shared with third parties inside/outside the company. The Internal Audit and Control Directorate has the mentioned authority alone in accordance with the precedent decisions of the Constitutional Court and the Supreme Court, The Law on the Protection of Personal Data and related legislation and the relevant articles of the Aydem Energy Information Security Policy.

Respect at  Work Place and Busıness Life

Acting With Respect and Thoughtfulness in Our Relationships with Others 

As Aydem Energy, our main goal is to approach our employees with respect, thoughtfulness and understanding and to create an environment that will contribute to provide total communication at all levels. We encourage open discussion of business-related issues and find solutions to these problems. 

Developing team spirit within the company, protecting corporate identity and improving it should be adopted as a common goal. All our employees are obliged to create and maintain an atmosphere in the workplace that complies with all values specified in this guide. 

The Aydem Energy provides employment opportunities for people who vary in terms of race, religion, nation, gender, sexual preference, marital status, age, seniority, family etc. Our employees need to value these diversities and maintain their relations with each other in line with the principles of mutual respect, justice, courtesy, honesty and equality. 

Company personnel should not disturb each other in public areas reserved for employees (including service vehicles). In these areas, except as the ones permitted by management, posters, handwriting and notes should not be posted; selling of goods and services should not be carried out. 

It is also unacceptable for one employee to be harassed by another employee directly or indirectly by telephone, e-mail, etc. Harassment includes, but is not limited to the following behaviors: 

• Defining members of a particular group with insulting expressions, 
• Negative classifications, humiliating jokes, offensive expressions, 
• Sneering pictures or cartoons that humiliate a particular group or person,
• Any humiliating words or physical attacks affecting the relationship between employees by creating a restless and hostile work environment,
• To exhibit physical or verbal behaviors contrary to the discreet relationship required by the working environment, to correlate the sexual preference of the employee with promotion at work, performance assessment, co-operation with colleagues, etc. or to threaten them,
• Any kind of undesirable sexual approach, sexually explicit offers or other statements and suchlike acts. 

No offensive and/or vengeful behavior shall be exhibited against employees who report harassment or inappropriate behaviors exhibited in the work environment to the relevant management and/or Code of Ethics Advisor. In addition, our managers are required to manage such situations confidentially. 

In case of any kind of harassment or offensive, incriminating attitude and behavior that causes a problem leading workforce decrease and performance decrease in the corporation or if any of our employees think that they have been subjected to similar behavior by their friend that they work with, manager or customer; Code of Ethics Advisor and Human Resources Management should be informed.

Our Principles About Harassment and Mobbing

Any breach of privacy through physical, sexual and/or emotional harassment shall not be tolerated at the workplace or at any place where they are on business towards our employees or our stakeholders with whom we have business relationship through our employees. Possible negative attitudes and behaviors towards those who report such violations or assist in the investigation are considered as a violation of our code of ethics. 

There is no tolerance to systematic and planned behaviors aiming to disincline the target person from work, decrease performance, and lead to resignation in a way to be evaluated within the scope of mobbing. 

Attitude/Behavior and Appearance 

As an employee of Aydem Energy, we must be friendly, caring and respectful to everyone in the working environment, in a clean, attentive, proper way of dressing in professional working life.  

We should represent Aydem Energy, which is the faithful corporation with behaviors and appearance in the best way. This principle is extremely important in terms of improving customer relations and increasing the respectability of the corporation and must be meticulously fulfilled. 

Creating a team spirit within the company, preserving and improving the company image is the common goal that plays an important role in the workplace and in the personal life of each employee. In order to prevent negative reflections on our business and/or the image of the company, we must demonstrate a balanced and harmonious attitude both professionally and financially.

We must also respect equally in our external relationships, to our customers, potential customers, shareholders, and the communities that we provide service. This requires gentle service, ethical business conduct, and compliance with all laws and regulations. As employees of a customer-oriented corporation, we have a responsibility to act in a way that creates positive impressions about Aydem Energy. 

We must comply with the standards of accuracy in high levels in our daily tasks of business, and strive to do our best in order to ensure that we achieve Company goals and objectives. By using time correctly during the working time, we must ensure that our special jobs are completed in short time so as not to interfere with customer transactions.

Ensuring Hierarchy Inside Company

The development of the employees has a great contribution to achieving the goals of Aydem Energy. Managers should manage employees based on professional criteria and recognize equal opportunities for development and rewarding for all employees in relation to their contribution to the success of the company. Managers who coordinate specific tasks or departments should exercise the competencies designed for their work in a balanced, impartial manner and with respect to the personal dignity of staff. For any purpose, our managers should avoid to do and/or have someone do a work outside their authority by exploiting their position and responsibilities. Our managers must constantly support the professional development of employees. 

Within the framework of honest and discreet management principles, the managers are responsible for proposing and realizing management manners that will increase the values of the company, provide maximum profit to the Company and protect the rights of employees in the long term. 

Employees should work in a manner that ensures cooperation in maximum level with their managers by avoiding behaviors that do not comply with the business principles. 

As a general principle, our employees are responsible for following the instructions of their superiors. However, our employees are not obliged to follow the instructions that may harm the profitability, efficiency and reputation of Aydem Energy or that do not comply with the Company's principles and legislation related to the subject matter. Employees who are of the opinion that the instructions are contrary to the legal and/or internal regulations or are harmful to the Company shall submit this opinion to the superior of the instructing senior manager and Code of Ethics Advisor. The employee who fulfills the instructions should immediately notify the Internal Audit and Control Directorate regarding the case if he/she believes that his/her transaction as per the instruction constitutes an offense as clearly stated in the relevant laws and regulations and/or will cause harm to the Company. 
Relationships between different levels of tasks should be regulated within the rules of mutual loyalty and respect created by the hierarchy (Inside the company and respectful to company values and objectives).

Workers with Kinship Relation

Our colleagues with the following degree of kinship relation may not be assigned as directly reporting to the same manager in any department of the Company. 

• Spouse, mother, father, children, siblings, uncle, aunt and their spouses and children, 
• Spouse’s mother, father, siblings, uncle, aunt and their spouses and children, 

All transactions involving family members and relatives of employees are performed by other employees who are not involved in such transactions.

At the same time, in order to ensure maximum transparency in all work, our employees should inform Human Resources Management if one of their family members (if blood relation is in question) has contact or make contact with the Company. 

Compulsory Attendance 

Our employees are obliged to pay attention to the working hours determined for the workplace and to use the personnel attendance control system at the entrances and exits (card scan, fingerprint scan, etc.). It is essential that the employee is in place during working hours. 

The employee who leaves his/her place of duty for any reason should inform the manager or his/her closest colleague to convey to the person to whom he/she is attached. 

The employee, who should be out of the company as a matter of duty, should inform his/her manager about his/her destination and the hours he/she will spend outside.

Information Sharing with Colleagues – Take-over Obligation

Employees who leave their duties permanently or temporarily cannot leave their duties unless they hand over the money and money-equivalent values, documents, tools and materials that they have to keep and use. This principle also applies to those who are temporarily assigned to other duty.
If the company suffers a loss due to the non-performance of the take-over duties, the causing persons shall be held responsible. 

Equality in Opportunity / Providing Equal Opportunities in Employment 

Aydem Energy aims to create a working environment that values the talents and experiences of each individual, respects differences and recognize the ideas and opinions of each employee. 

Respect for differences is not only the right way to do our job, it is also essential for the success of our business. 

Aydem Energy does not allow discrimination among its employees. It ensures that all personnel practices are conducted on the basis of individual ability and merit, regardless of race, religion, color, age, gender, national origin or lineage, sexual preference, physical disability, seniority or other factors determined and protected by law. These applications include but are not limited to employment, selection, performance management, training, placement, transfer, promotion, disciplinary punishment and cancellation of labor contract. 

Workplace Security and Healty

Occupational Health and Safety (OHS) and Protection of Environment 

The Company is obliged to provide maximum OHS conditions to all its employees, to provide training and deliver equipment. Likewise, employees are obliged to participate fully in related trainings and take all necessary precautions regarding the subject matter. All employees should notify their manager of any possible dangers they see in their workplaces, either in writing/verbally and/or by filling out the “Near-Miss” form. It is the responsibility of the process owners for OHS and Human Resources Management to share the lessons to be learned about occupational accidents in the field.  Employees are obliged to comply with Aydem Energy Occupational Health and Safety and Environmental Policies and the details specified in the relevant legislation. 

OHS incidents are reported to relevant authorities in a transparent and proper manner in accordance with the legislation and Company policies/principles. 

Keeping and Bearing Arms 

Employees, customers and visitors are not allowed to carry weapons in their workplaces except for those who are carrying weapons due to their duties. (Security Staff, etc.) 

In the controls at the building entrances, our colleagues are necessarily required to have the necessary controls without title distinction. 

Carrying weapons with special reasons and armed entry of visitors are only possible with the permission of Human Resources Management. 

Using Drugs 

It is strictly prohibited to use any substance (alcohol, drugs, etc.) that may affect the work performance of our employees or compromise workplace safety. This prohibition also includes being affected by these substances, which may adversely affect the employee's work performance at the time of entering Aydem Energy buildings. 

Betting and Gambling

Employees may not engage in activities such as betting or gambling that could damage public reputation of the Aydem Energy Company. 

Procurement of gambling devices, to prepare and to participate any kind of gambling activity such as preparing draw with any type of goods and money prize or preparing games, buying/selling tickets for such games are prohibited for all employees.

Scope and  Codes of Pratice

Aydem Energy Code of Ethics and Business Principles were published by the Board of Directors and are reviewed once a year in line with the needs, changing conditions and current practices. 

Violation and Results of Code of Ethics and Business Principles

The Code of Ethics and our Business Principles are among key factors in our reputation and continuous success in the industry. Violation of these rules and principles may adversely affect our reputation and success in the industry. Therefore, it is within the scope of ethical review or disciplinary investigation to behave in an unethical way contrary to our honesty principle or to act against the business principles. All our employees are obliged to comply with these rules. 

Our employees are obliged to carry out their responsibilities in accordance with the applicable written laws, regulations and legislation and general tendencies. Our employees may not engage in any illegal activity or inform anyone in this manner while carrying out their responsibilities in the Company or performing their daily business. 

Any violation of laws, corporate principles or code of ethics such as non-cooperation in an investigation, may be the subject of ethical review or disciplinary investigation. 

Tasks and Responsibilities of Code of Ethics Advisor

The top manager in charge of Human Resources management of each company within Aydem Energy is Code of Ethics Advisor. Code of Ethics Advisors are responsible for; 

• Guiding and advising on questions and issues raised by employees in the company on ethics, 
• Directing ethical nonconformities to the Ethics Committee that cannot be resolved within the company or resolution of which requires ethical review or disciplinary investigation,  
• Contributing to the resolution of the internal ethical nonconformities in line with the demand of Ethics Committee,
• Reporting the ethical questions and nonconformities with the results to the Ethics Committee regularly or upon request,
• Being the contact person of the company in the ethical review and investigations requested by the Ethics Committee and giving necessary support to the reviews and investigations carried out by the Internal Audit and Control Directorate, 
• Monitoring and tracking the effectiveness of the ethical practices carried out in the company and to support the practices.

Tasks and Responsibilities of Managers 

Aydem Energy managers have also additional responsibilities beyond the responsibilities defined for employees within the framework of the Code of Ethics and Business Principles. Hereunder, managers are responsible for;
• Ensuring the creation and maintenance of a company culture and work environment that supports code of ethics,
• Being an example to the implementation of code of ethics with behaviors, educating employees on code of ethics,
• Supporting employees in conveying their questions, complaints and notifications about code of ethics, 
• Giving guidance on the actions to be taken when consulted, taking into account all notifications and forwarding them to the Ethics Committee as soon as possible when necessary,  
• Ensuring that the business processes under his/her responsibility are structured in a way to minimize the risks related to ethical issues and applying the necessary methods and approaches to ensure compliance with the code of ethics.

Resolution of Incompatibilities 

Ethics Committee Organization 

Incompatibilities in ethical issues are resolved within the Aydem Energy Ethics Committee.

The Ethics Committee consists of the Chairman, Group Human Resources Senior Manager and Group Legal Senior Manager. The Ethics Committee evaluates violations by taking into account the ethical review and disciplinary investigation reports prepared by the Internal Audit and Control Directorate. The functioning of the Ethics Committee, decision-making processes, relations with Disciplinary Committees in companies and reporting practices are described in detail in the Disciplinary Practices Procedure.

Notifications of Violations and Business Principles of Ethics Committe

The Ethics Committee conducts its activities within the framework of the following principles: 

• Notices and complaints and the identity of those making the notification or complaint are kept as confidential. It adopts a policy that prevents possible retaliatory attitudes and behaviors towards employees or individuals who report ethical violations. 
• Conducts reviews and investigations in confidentiality rules. 
• It has the authority to request information, documents and evidence related to the review and investigation directly from the existing unit. It may examine any information and documents obtained only limited to the subject of the investigation. 
• The review and investigation process is linked to the written report from the beginning. Information, evidence and documents are attached to the report. 
• With the examination, the notifications subject to the investigation are dealt with immediately and the result is reached as quickly as possible. 
• Decisions taken by the Committee shall be implemented immediately. 
• The relevant departments and authorities are informed about the result. 
• The chairman and members of the Committee shall act independently and unaffected by the department managers and the hierarchy within the corporation while performing their duties on this matter. No pressure or suggestion shall be applied to them. 
• The Board may seek expert opinion if it deems necessary and may benefit from the experts by taking measures that will not violate the principles of confidentiality during the review or investigation. 

You can use the following communication channels or contact Ethics Committee members directly for your questions and notifications. 

e-mail:  etik@aydemenerji.com
Telephone:  0 (850) 575 0 575 
Post delivery: Adalet Mahallesi Hasan Gönüllü Bulvarı No: 15/1 Merkezefendi / Denizli (to the Ethics Committee Chairmanship)