Page 37 - Nurol YES Sustainability Report

Occupational Health and Safety and Environmental Risk Assessment

Works on determining the OHS hazards and assessing their risks, as environmental accidents, occupational accidents or occupational In case we think that there is any violation of Codes of Conduct Nurol Construction has procured services from a specialized
well as the environmental aspects are determined through the "Risk disease, any occurrence seriously e ecting the environment and defined in Code of Governance; a notification phone line is established consultancy company for the process of compliance with the Personal
Assessment Procedure". We carry out these works in our headquarter occupational health and safety, any incompleteness in actions. for notices of the employees. All announcements related with the Data Protection Law (KVKK) since 2018. Following a current due
and all our projects in accordance with our procedure, which explains usage of Ethics Notification Phone Line are posted on the notice diligence study that includes all of its processes, our processes started
the principles of determining and managing risks in OHS-E issues. We Risk Assessment Groups are formed for OHS-E Risk Assessment boards. to be managed in accordance with the principles of KVKK. We
follow the risk control methods determined to manage risks and share works. In the groups; Project Manager, Representative of the identified personal data in our processes through data o cers and
our risk assessment results with all our subcontractors working in our Employer, Occupational Physician, Occupational Safety Specialist, All employees are liable for notifying the company via Nurol corporate entered them in to Data Responsibles Registry Information System
field. Representative of Employees, Support Employees, representatives website (www.nurol.com.tr), etik.bildirim@nurol.com.tr, Ethics and (VERBİS) in order to define and manage business processes and
from related departments and employees from related departments Discipline Committee and Ethics Representative and/or related compliance strategies regarding personal data use. In this context,
OHS-E risk assessment is revised at least once a year. It is also revised are the participants. The Risk Assessment Team is trained on the risk Company General Manager for any suspicions of violation of these our personal data are stored confidentially in the database and
and updated in case of: new equipment or machinery buy outs which assessment methodology before starting the work, and e orts to policies or legislation being subjected to. Notifications can be via systems in our company, in accordance with the law, and are not
might e ect both environment and health and safety of employees, increase the competencies of the people on the steps to be followed phone 0 312 455 10 05 directly to our Ethics Notification Phone Line. shared with third parties in any way except legal obligations. As Nurol
new technic developments, changes in organization or work flow, new in the risk assessment are constantly improved. Construction, we prevent unauthorized access to the systems and
raw material or semi-manufactured goods production process, All notifications are anonymous and notifiers are not disclosed under databases where personal data is kept, and we implement software
no circumstances whatsoever. During notification and investigation and physical security measures such as access management. In the
period, confidentiality, objectivity and compliance to codes of conduct recruitment processes, we inform our employees about our personal
is crucial. In case of any intentional and inaccurate notification, it will data protection practices and receive clear consent text from them.
ETHICS MANAGEMENT be treated as violation of codes of conduct. We act in accordance with the confidentiality principles determined by
The practices applied forthe compliance to Code of Governance are
reviewed by Nurol Construction Internal Control and corrective the Employer in sharing information and documents with third parties
that we had received from the Employer. In cases where the
Policies and Principles for Practice measures are taken in case of any detection of misconduct. information of the employer needs to be shared, confidentiality
agreements are drawn up with the parties, including these
Codes of Conduct prepared for Nurol Group Companies include all standards and mindset for business relations and transactions of Nurol Violations are reviewed, solved and reported by Ethics and confidentiality clauses. At Nurol Construction, there has been no
Construction. The principles are binding and explanatory for risk management, working principles, ethical principles and internal control. Discipline Committee. violation of confidentiality of Employer information, and there has
been no warning or complaint from the Employers.
These rules determine the ethical working principles and the principles that every employee must follow, regardless of where they are or their
title, and apply to all employees of Nurol Construction. All employees regardless of the location should act accordingly and properly during the
relations with all our stakeholders (other employees, customers, suppliers, subcontractors, shareholders and competitors, etc.). Adherence to the
codes of conduct is the core for the reputation and the success of our company. Codes of conduct is our reference for all our actions & operations; Ethics and Discipline Committee
we own them to represent our company as a model. In the light of this approach, we avoid any misbehavior which might a ect our company
reputation adversely. There are five basic principles of ethical rules and working principles: Ethics and Discipline Committee is formed to implement, execute, Nurol has adopted the principle of complying with laws and other
own and discipline the "Code of Governance" of Nurol and Ethics regulations within the context of anti-bribery and anti-corruption
Committee is responsible from running the principles and practices. laws, universal law, ethical and professional principles in all countries
Ethics and Discipline Committee (EDC) consist of 5 members, Human where it operates and is represented. Under this principle, it is
Rules and Working Principles Resources Coordinator, Nurol Company Chief Counsel, Nurol Company committed to maintaining its activities in a fair, honest, legal and
Human Resources Manager and 2 members from Internal Control ethical manner. Nurol explicitly prohibits bribery and corruption, which
Department. The working procedures and can take place in many ways, such as facilitation
principles of the Ethics and Discipline Committee payments, gifts, representation and entertainment,
are defined by the “Nurol Ethics and Discipline lobbying activities, political support and donations.
Accountability Honesty Integrity Clarity Respect Committee Working Procedures and Principles Combating bribery and corruption is an act that
We are all responsible Nothing counts We walk the talk Sincere and direct We respect all individuals Directive”. requires legal punishment as well as business ethics,
from our own actions like reality answers to and treat in a dignified, and it is expected that our employees shall
questions respectful and thoughtful Compliance to rules is under the responsibility of
manner demonstrate sensitivity and deem this e ort as a part
Nurol Group Board of Directors and Nurol Ethics of their personal duties and responsibilities
and Discipline Committee is responsible from independent of business life. At the same time, our
Codes of Conduct execution. Nurol Company Board of Directors and company has established control systems to prevent
EDC revise the Codes of Conduct considering the
informal transactions by protecting the legal rights of
Nurol Codes of Conduct is as below: developments once a year. The results and our government institutions, suppliers, customers,
recommendations shared with Board of Directors. employees and other stakeholders we work with. Our
Human Resources and Employee Relations Product/Service Quality and Safety Lobby Activities, Political Support employees are responsible for notifying their managers or o cers via
Customers, Suppliers and Subcontractor Relations Environmental Awareness and Political Donation The Ethics Discipline Committee is responsible for ensuring the ethical the Ethics Hotline immediately, about any situations they encounter
and reputation management and development of Nurol, to examine
Asset Security and Protection Respect to Law and Compliance to Regulations Sponsorships the notices and notifications that contain contradictions or suspicions or suspect regarding bribery and corruption.
Nurol owned Information Protection Anti-Corruption and Bribery Disaster Management of ethical rules, to present them to the Holding Board of Directors by When we compare the requirements and practices of “Nurol
Fraud Prevention, Accurate Accounting Recording Facilitation Payments Risk Management preparing corrective action suggestions, and to prepare ethical Holding Anti-Corruption and Bribery Regulations”, which are an
and Accuracy of Company Books Gifts, Representation and Hosting Operational Excellence Declaration compliance and awareness programs based on code of governance . integral part of the Code of Governance and sustainability targets,
Conflict of Interest Consultants Social Responsibility and Volunteerism When members of EDK receive any complaint/violation notification, and our activities in 2019 and as a result of the Ethical Reporting
Honest Communication with Society and Media Working with Partners and Charity Donations they assure the complainant that all the notifications to be shared will Line evaluations; it is observed that there has been no corruption
Occupational Health and Safety Other Working Arrangements Violation Notifications be protected, and their name is kept confidential upon request of the incident in our company's HQ and projects.
complainant. Confidentiality and security measures are taken for
those who are in charge or support the investigation.

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