Page 33 - Nurol YES Sustainability Report
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CODES OF CONDUCT
                                                                                                                                 Nurol Codes of Conduct is as below:


                                                                                                                                         Human Resources and Employee Relations         Facilitation Payments
                                                                                                                                         Customers, Suppliers and Subcontractor Relations  Gifts, Representation and Hosting
                                                                                                                                         Asset Security and Protection                  Consultants
                                                                                                                                         Nurol owned Information Protection             Working with Partners and Other Working Arrangements
                                                                                                                                         Fraud Prevention, Accurate Accounting Recording and   Lobby Activities, Political Support and Political Donation
                                                                                                                                         Accuracy of Company Books                      Sponsorships
                                                                                                                                         Conflict of Interest                            Disaster Management
                                                                                                                                         Honest Communication with Society and Media    Risk Management
                                                                                                                                         Occupational Health and Safety                 Operational Excellence Declaration
                                                                                                                                         Product/Service Quality and Safety             Social Responsibility and Volunteerism
                                                                                                                                         Environmental Awareness                        Charity Donations
                                                                                                                                         Respect to Law and Compliance to Regulations   Violation Declarations
                                                                                                                                         Anti-Corruption and Bribery

                                                                                                                                 In case of any violation thought considering the Codes of Conduct   During notification and investigation period, confidentiality,
                                                                                                                                 defined in Governance Principles; notice line exists for declarations of   objectivity and compliance to codes of conduct is crucial. In case of
                                                                                                                                 the employees. All announcements related with the usage of Ethics   any intentional and inaccurate notification, it will be treated as
                                                                                                                                 Notice Line are already on the notice boards.         violation of codes of conduct.
          ETHICS MANAGEMENT                                                                                                      All employees are liable for notifying the company via Nurol   The practices, during the compliance to Governance Principles,
                                                                   CODES OF CONDUCT AND                                          corporate website (www.nurol.com.tr), etik.bildirim@nurol.com.tr,   reviewed by Nurol Construction Internal Control and corrective
                                                                                                                                 Ethics and Discipline Committee and Ethics Representative and/or
                                                                                                                                                                                       actions taken in case of any detection of misfit.
          POLICIES AND PRINCIPLES FOR PRACTICE                       WORKING PRINCIPLES                                          related Company General Manager for any doubts of violation on   Violations are reviewed, solved and reported by Ethics and
          Codes of Conduct prepared for Nurol Group of                                                                           these policies and principles. Notifications can be via phone   Discipline Committee.
                                                                                                                                 +90 312 455 10 05 directly to our Ethics Notice Line.
          Companies includes all standards and mindset                                                                           All notifications are anonymous, any notifier is not disclosed.
          for business relations and transactions of                       Accountability
          Nurol Construction. The principles are binding                   We are all responsible from
          and explanatory for risk management,                             our own actions
          working principles, ethical principles and                                                                             ETHICS AND DISCIPLINE COMMITTEE
          internal control.                                                                                                      Ethics and Discipline Committee is formed to put into practice, apply,   Compliance to rules is under the responsibility of Nurol Group Board
          The principles are binding for all employees of                  Honesty                                               own and discipline the ‘Governance Principles’ of Nurol and Ethics   of Directors and Nurol Ethics and Discipline Committee is responsible
          Nurol Construction regardless of the title and                   Nothing counts like reality                           Committee is responsible from running the principles and practices.   from execution. Nurol Company Board of Directors and EDC revise
          location and defines ethical working principles                                                                         Ethics and Discipline Committee (EDC) consist of 5 members, Human   the Codes of Conduct considering the developments once a year. The
          and essentials. All employees regardless of                                                                            Resources Coordinator, Nurol Company Chief Counsel, Nurol Company   results and recommendations shared with Board of Directors.
          the location; should act accordingly and                                                                               Human Resources Manager and 2 members from Internal Control   According to evaluation results of 2018 activities & operations and
          properly during the relations with all our                       Honesty                                               Department. Working procedures and principles of Ethics and   Ethics Notice Line notifications under the light of Nurol
          stakeholders (other employees, customers,                        We walk the talk                                      Discipline Committee is defined by Nurol Group of Companies Ethics   Governance Principles, ‘Anti-Corruption and Bribery’ section, there
          suppliers, subcontractors, shareholders and                                                                            and Discipline Committee Working Procedures and Principles   is no anti-corruption incident both in HQ and projects.
          competitors, etc.).                                                                                                    regulations.
          Applying the codes of conduct is the core for
          the reputation and the success of our                            Transperancy
          company. Codes of conduct is our reference for                   Sincere and direct answers to questions
          all our actions & operations; we own them to
          represent our company as a model. In the light
          of this approach, we avoid any misbehavior                       Respect
          which might a ect our company reputation
          adversely.                                                       We respect all individuals and treat in a
                                                                           dignified, respectful and thoughtful manner






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