PROTEINOCEAN BUSINESS ETHICS POLICY
OUR BUSINESS ETHICS RULES AND APPLICATION PRINCIPLES
CONTENTS
1. General Information on Business Ethics Rules
1.1 Preface
1.2 Our Values
1.3 Rules of Business Ethics
1.4 Why Do We Follow a Code of Ethics?
1.5 Responsibilities of Managers
1.6 Responsibilities of Our Employees
1.7 Responsibilities of Our Solution Partners
2. Ethical Rules for Employees and Employee Candidates
2.1 Recruitment Process
2.2 Working Conditions
2.3 Social Dialogue
2.4 Education
2.5 Diversity, Discrimination and Harassment
3. Business Ethics and Working Principles
3.1 Fighting Corruption and Bribery
3.2 Fair Competition
3.3 Conflict of Interest
3.4 Gifts and Invitations
3.5 Civil Society Organizations and Political Activities
3.6 Information Security and KVKK
4. Principles to be Applied in Case of Policy Violations
4.1 Ethical Violation Detection Assessment
4.2 Dispute Resolution in Case of Violation
5. Ethics Committee
5.1 Board
5.2 Ethics Committee Working Principles
5.3 Notification of Notice
1. GENERAL INFORMATION ABOUT BUSINESS ETHICS
1.1 Preface
Dear Proteinocean Employees,
Proteinocean Business Ethics Rules have been created to guide us in all our business processes in accordance with our core principles and values.
We are committed to operating within our company and maintaining our relationships with all our customers, suppliers, and solution partners, in accordance with the principles of honesty, reliability, transparency, and accountability, within the framework of the rules set forth in this guide. As Proteinocean Gıda A.Ş., we act with the awareness of establishing a corporate culture where everyone embraces the principles of ethical behavior. As representatives of Proteinocean Gıda A.Ş., we are responsible for reading and strictly adhering to the rules set forth in this guide.
In this new world order, where change is constantly changing and unpredictable, we successfully conduct our operations by integrating sustainability into all our processes. We understand that you will play an active role in achieving the sustainability goals we have set within the framework of ethical principles, and we will adhere to the rules in this guide.
I sincerely believe that you will comply and thank you for your support.
Proteinocean Food Inc.
Board of Directors
1.2 Our Values
• Truth
• Trust
• Honesty
• Pioneering
• Sustainability
• Responsibility
• Sense of Duty
1.3 Rules of Business Ethics
Ethical values are defined as unwritten moral rules. A Code of Business Ethics is a set of written standards designed to help us determine how we behave and make decisions both inside and outside the company.
These rules, prepared based on the basic principles and values of Proteinocean Gıda A.Ş., are for our colleagues, customers, suppliers and solution providers.
It forms the framework of our responsibilities to our partners.
In this guide, Proteinocean Gıda A.Ş. will be referred to as “Proteinocean”.
1.4 Why Do We Follow a Code of Ethics?
Proteinocean conducts its activities and relationships with all its customers, suppliers and solution partners in accordance with the ethical values it has adopted.
undertakes to achieve.
The Proteinocean Code of Business Ethics was published to foster a robust and sustainable corporate culture. The Code will guide us on how to address ethical issues that may arise in our business processes and provide a common language for us to speak.
Proteinocean Business Ethics Rules are the responsibility of all Proteinocean employees in every position, our solution partners, business partners, company representatives, consultants, etc.
Our groups are expected to comply.
1.5 Responsibilities of Managers
Leading the implementation and enforcement of the Code of Business Ethics is among the primary responsibilities of our managers. In addition to setting an example by adhering to these rules, it is also our responsibility to ensure that our employees receive the necessary training on these ethics and to provide an environment and conditions that will enable employees to freely report any violations.
1.6 Responsibilities of Our Employees
We expect our employees to read, understand, and implement the rules contained in this guide. Furthermore, all employees are obligated to comply with all applicable policies, regulations, procedures, and guidelines within our company.
In matters that are unclear or cannot be resolved, the department manager, the Human Resources Department, or the Ethics Committee should be consulted before taking any action. Our employees are committed to ethical conduct.
They must actively participate in training regarding the rules.
Our employees who suspect or witness a violation of the rules are required to report the situation to the Ethics Committee as soon as possible.
1.7. Responsibilities of Our Solution Partners
As Proteinocean, we undertake to comply with the ethical rules we adhere to in our relations with all our stakeholders with whom we interact, and we also expect our stakeholders to comply with the same.
We are waiting.
2. ETHICAL RULES FOR EMPLOYEES AND EMPLOYEE CANDIDATES
2.1 Recruitment Process
At Proteinocean, we provide equal opportunity to candidates during recruitment. We do not discriminate based on factors such as race, color, gender, religion, language, marital status, sexual orientation, gender identity, political views, ethnicity, health status, family responsibilities, union activity or membership, physical disability, or age. Managers who make hiring decisions may not hire spouses, close relatives, or relatives of these individuals.
2.2 Working Conditions
Ensuring that our employees benefit from fundamental human rights and laws is always among our priorities.
Working hours, leave periods and rest periods are determined in accordance with the Labor Law and are regulated in detail in employment contracts.
Proteinocean's compensation policy is based on values that encourage sustainable success, based on fair, measurable, and balanced performance targets. Employees are not paid less than the minimum wage specified in the Labor Law.
While ensuring that our employees fully and correctly use their personal rights, we maintain a balance between work and private life.
We provide our employees with a healthy and safe work environment. Increasing employee loyalty and ensuring sustainable productivity are made possible through employee satisfaction. To this end, the Proteinocean Ethics Committee conducts regular employee satisfaction and loyalty evaluations throughout the year, and where necessary, adjustments are made.
improvement programs are being implemented.
2.3 Social Dialogue
All our employees work within predetermined teams, adhering to activity plans and workflow regulations. Our company's human resources representatives ensure effective dialogue between management and employees. All our business planning is organized to provide sustainable service to our customers within an effective oversight mechanism.
2.4. Education
We provide our employees with equal access to training. We ensure that employees receive training on the processes they operate, contributing to their performance. Training on codes of ethics ensures that our employees adhere to ethical values and act accordingly.
2.5 Diversity, Discrimination and Harassment
At Proteinocean, we value diversity, diverse perspectives, talents, and experiences, and we encourage this in our employees. Our employees are obligated to respect diversity in their dialogue with each other and our stakeholders.
We are committed to providing a fair, safe and healthy working environment for our employees, without discrimination based on factors such as race, color, gender, religion, language, marital status, sexual orientation, gender identity, political views, ethnic identity, health status, family responsibilities, union activity or membership, physical disability, age or pregnancy during recruitment, employment relations, discipline, promotion, salary determination, working hours, complaints and dismissal.
Physical, psychological violence, verbal harassment, or sexual abuse is strictly prohibited at our company. Our employees' private and family lives are respected. They are not forced to discuss private or sensitive matters with managers. Any violation of our employees' privacy through physical/psychological violence, sexual/emotional harassment, or harassment, whether at the workplace or anywhere else they are employed, is against both the law and ethical principles. No employee is permitted to be subjected to restrictions, interventions, coercion, or retaliation for reporting a violation or providing counseling or testimony. Systematic and planned behaviors intended to alienate the targeted individual from work, reduce their performance, or cause them to resign, which would be considered psychological harassment (mobbing), will not be tolerated.
3. BUSINESS ETHICS AND WORKING PRINCIPLES
3.1 Fighting Corruption and Bribery
At Proteinocean, we are committed to meeting standards of honesty and fairness in all our internal and external relationships, in accordance with national and international laws against corruption and bribery.
It is essential to comply with laws, regulations, and principles against all forms of bribery and corruption, and to avoid continuing business relationships with third parties (outsourced companies and business partners) who demand or offer bribes/corruption. Accepting, giving, or offering bribes, regardless of the purpose, is unacceptable.
No employee may receive benefits from, enter into private business relationships with, or request or make payments to third parties or organizations related to their work. All employees are obligated to comply with anti-corruption and anti-bribery rules and to report any violations to the relevant authorities.
3.2 Fair Competition
Proteinocean recognizes the importance of a competitive market and is committed to complying with all rules and regulations regarding competition and transparency, particularly Labor Law No. 4857 and Turkish Commercial Code No. 6102, in all our activities and operations. Our employees are responsible for complying with competition laws in all areas of our operations and not violating the intellectual property rights of third parties.
3.3 Conflict of Interest
A conflict of interest is a matter that can negatively impact the corporate identity and reputation. Proteinocean employees must avoid any conflict of interest and/or any other interests, whether their own or those of third parties. Situations that could give rise to a conflict of interest are listed below:
• Employees accepting money or providing benefits or advantages from third-party individuals or companies (current or potential competitor, customer, supplier, subcontractor or representative, etc.) that have a business relationship with Proteinocean,
• People who have family or up to third degree relatives have commercial relations with our company,
• Managers who have to make hiring decisions hire their spouses, close relatives and relatives of these individuals,
• Employees using their duties and authorities for personal and private gain for themselves, their families or third parties,
• Use of company assets, resources, facilities and personnel for personal benefit outside the company.
3.4 Gifts and Invitations
At Proteinocean, we prioritize maintaining professional relationships with third parties and ensuring they do not influence business decisions. Therefore, our employees are required to refrain from engaging in relationships with third parties, including customers, suppliers, and business partners, that could create a conflict of interest when offering or accepting gifts, invitations, or entertainment. The following rules are required of our employees in this regard:
• No gift should be accepted or offered that creates the impression of irregularity, that may cause or be perceived as a dependency relationship (providing privileges or references, ensuring the winning of a tender, etc.), except for gifts given in accordance with legal and commercial customs, traditions and traditions, or as souvenirs/promotional materials.
• With the knowledge of the management, appropriate products and services may be accepted as gifts and/or products or services that are compatible with the recipient's culture and ethical values may be given as gifts,
• In seminars and similar organizations attended on behalf of our company, gifts such as awards, plaques and similar gifts of symbolic value may be accepted as a memento of the day, in addition to cash.
• Promotional gifts and promotions approved by our company's management to our customers, suppliers and other third parties with whom we have business relations.
Gifts other than materials should not be given,
• Manager approval must be obtained for participation in invitations such as sporting events, domestic/international trips, etc. that are influential in decision-making or could be perceived as such, other than conferences, receptions, promotional events, seminars, etc. open to general participation organized by individuals or institutions with whom one has a business relationship.
3.5 Civil Society Organizations and Political Activities
Proteinocean approaches civil society organisations and political parties with the principles of integrity, honesty and impartiality.
Membership in any non-governmental organization and participation in its activities on behalf of Proteinocean may be undertaken with the knowledge of the management.
Proteinocean's resources may not be used to make in-kind or cash donations and/or support any political party or candidate. Propaganda, demonstrations, or similar activities are prohibited within the boundaries of any company-owned premises. Our employees must not engage in any political activities during working hours and must not take up the time of their colleagues in these activities. Our company respects the right of our employees to participate individually in political activities, provided they clearly state that they do not represent the company.
3.6 Information Security and KVKK
As Proteinocean, we consider information security to be among our top priorities and our company complies with the Information Security Rules and the Personal Data Protection Law (KVKK).
We act accordingly.
We are obligated to act with the understanding that our company's financial and trade secrets, employee rights and information, and agreements with our customers, suppliers, and business partners are subject to confidentiality. We are obligated to protect and maintain their confidentiality and not to share them with unauthorized individuals or authorities, both inside and outside the company. We are responsible for the data security of desktop and/or laptop computers entrusted to us, and we must use personal information we access for business purposes in accordance with the Personal Data Protection Law.
No one other than our company's senior management or authorized individuals may publish, interview, give statements, give conferences, or provide information about Proteinocean. Our employees must not share any confidential information related to our company's intellectual and industrial property rights with third parties. If sharing is necessary, they must take the necessary precautions to protect our rights in accordance with relevant procedures. Confidential files cannot be taken outside the company. Approval must be obtained from the person responsible for the information or senior management for confidential files or information that must be taken outside the company.
Passwords, user codes and similar identifying information used to access information about the company must be kept confidential and not shared with anyone other than authorized users.
Our employees must keep and archive records related to their work within the legal periods and must not respond to confidential information requests from third parties without the approval of senior management.
Proteinocean values the confidentiality of information belonging to its customers, suppliers, solution partners, and third parties with whom it has relationships. We must avoid knowingly and unauthorized unlawful use of our business partners' patents, copyrights, trade secrets, trademarks, computer programs, or other intellectual and industrial property rights. In keeping with the principles of fair competition, competitor information should be collected and used only from publicly available sources. The source of the information should be documented to ensure its legitimacy.
Our employees' salaries, fringe benefits, and other personal information are kept confidential and are not disclosed to anyone other than authorized personnel. Employee information is sent privately. Employees must not disclose this information to others, nor must they be pressured to disclose it.
4. Principles to be Applied in Case of Policy Violations
4.1 Ethical Violation Detection Assessment
If you have any questions about the principles outlined above, be sure to develop an action plan. Following the steps below and asking yourself these questions will guide you in deciding on an action plan, ensuring the system operates much more effectively. If you feel it's necessary, you can contact senior management.
A) Identifying the Event, Decision, or Problem
• Have you been asked to do something that you think might be wrong?
• Are you aware of a potentially illegal or unethical situation within our company or among your customers?
• Are you trying to make a decision and have doubts about how to act in accordance with business ethics?
B) Think Before You Decide
• Try to clearly define and summarize your problem or question.
• Ask yourself why there is a contradiction
• Consider options and consequences
• Consider who might be affected
C) Decide on a Plan of Action
• Determine your responsibilities
• Review all relevant facts and information
• Refer to our company policies, procedures and principles
• Assess risks and think about how you can reduce them
• Try to create the best action plan
D) Test Your Decision
• Review the ethical questions that need to be asked
• Review your decisions within the framework of the company's core values
• Make sure you comply with company policies, laws, and professional standards.
• Consult with qualification holders and consider their views within your planned action plan.
E) Continue with determination
• Share your decision with the relevant people along with your reasons. Share what you have learned.
• Share your success story with others
F) 4 Basic Questions to Consider
• Is this activity/behavior in accordance with laws, rules and customs?
• Is this activity/behavior balanced and fair? Would we be uncomfortable if someone else did it?
• Is there another course of action that would not create an ethical conflict?
• Who might be affected by this activity/behavior? Will there be a negative reflection on you or our company?
4.2 Dispute Resolution in Case of Violation
Those who violate the Code of Business Ethics or our Company's policies and procedures will be subject to various disciplinary sanctions, up to and including termination of employment. This policy is an integral part of and an annex to the employment contracts we have signed with our employees. Disciplinary sanctions will also apply to those who approve, direct, or have knowledge of inappropriate behavior or actions that violate the rules and fail to properly report them.
5. ETHICS BOARD
5.1 Board Members and Responsibility
The Ethics Committee is responsible for investigating and resolving complaints and reports of violations of the Code of Ethics. The Ethics Committee consists of individuals in the following positions:
* President – Chairman of the Board of Directors
* Member – Board Member
* Member – Human Resources Manager
If the person to whom the notification is made is a board member, the Chairman of the Board may appoint another person to the board instead of this person, if deemed necessary.
5.2 Ethics Committee Working Principles
The Ethics Committee carries out its work within the framework of the principles set out below:
• Keeps the identities of those making notifications and complaints confidential.
• Conducts the investigation as confidentially as possible.
• Has the authority to request information, documents, and evidence related to the investigation directly from the relevant unit. Any information and documents obtained may be examined only within the scope of the investigation.
• The investigation process is recorded in a written report from the outset. Information, evidence, and documents are added to the report.
• The minutes are signed by the chairman and members.
• The investigation is handled with urgency and the result is reached as quickly as possible.
• The decisions taken by the Board are implemented immediately.
• Relevant departments and authorities are informed about the results.
• While performing their duties on this matter, the chairman and members of the board act independently and without being influenced by the department managers to whom they are affiliated and the hierarchy within the organization.
• If deemed necessary, the Board may seek expert opinion and utilize experts by taking precautions that will not violate confidentiality principles during the investigation.
• The Board is responsible for the implementation and monitoring of the Business Ethics Rules and for making changes to other policies and articles it deems necessary.
5.3 Notification of Notice
At Proteinocean, we prioritize the sustainable implementation and adoption of our ethical principles to establish and maintain a culture of ethical behavior within our company. We guide our employees to report any identified or suspected violations of law, policy, or ethics in good faith, confidentially, and without facing any retaliation or victimization.
In this context, notifications to be made to the Ethics Committee;
* E-mail to be sent to maria@carecorner.cc
* Written submissions must be made in a sealed envelope to the address “Ostim OSB Mah.1268 cd. no:11 Yenimahalle/ANKARA” with the title “Proteinocean Ethics Committee”.
PROTEINOCEAN BUSINESS ETHICS POLICY
OUR BUSINESS ETHICS RULES AND APPLICATION PRINCIPLES
CONTENTS
1. General Information on Business Ethics Rules
1.1 Preface
1.2 Our Values
1.3 Rules of Business Ethics
1.4 Why Do We Follow a Code of Ethics?
1.5 Responsibilities of Managers
1.6 Responsibilities of Our Employees
1.7 Responsibilities of Our Solution Partners
2. Ethical Rules for Employees and Employee Candidates
2.1 Recruitment Process
2.2 Working Conditions
2.3 Social Dialogue
2.4 Education
2.5 Diversity, Discrimination and Harassment
3. Business Ethics and Working Principles
3.1 Fighting Corruption and Bribery
3.2 Fair Competition
3.3 Conflict of Interest
3.4 Gifts and Invitations
3.5 Civil Society Organizations and Political Activities
3.6 Information Security and KVKK
4. Principles to be Applied in Case of Policy Violations
4.1 Ethical Violation Detection Assessment
4.2 Dispute Resolution in Case of Violation
5. Ethics Committee
5.1 Board
5.2 Ethics Committee Working Principles
5.3 Notification of Notice
1. GENERAL INFORMATION ABOUT BUSINESS ETHICS
1.1 Preface
Dear Proteinocean Employees,
Proteinocean Business Ethics Rules have been created to guide us in all our business processes in accordance with our core principles and values.
We are committed to operating within our company and maintaining our relationships with all our customers, suppliers, and solution partners, in accordance with the principles of honesty, reliability, transparency, and accountability, within the framework of the rules set forth in this guide. As Proteinocean Gıda A.Ş., we act with the awareness of establishing a corporate culture where everyone embraces the principles of ethical behavior. As representatives of Proteinocean Gıda A.Ş., we are responsible for reading and strictly adhering to the rules set forth in this guide.
In this new world order, where change is constantly changing and unpredictable, we successfully conduct our operations by integrating sustainability into all our processes. We understand that you will play an active role in achieving the sustainability goals we have set within the framework of ethical principles, and we will adhere to the rules in this guide.
I sincerely believe that you will comply and thank you for your support.
Proteinocean Food Inc.
Board of Directors
1.2 Our Values
• Truth
• Trust
• Honesty
• Pioneering
• Sustainability
• Responsibility
• Sense of Duty
1.3 Rules of Business Ethics
Ethical values are defined as unwritten moral rules. A Code of Business Ethics is a set of written standards designed to help us determine how we behave and make decisions both inside and outside the company.
These rules, prepared based on the basic principles and values of Proteinocean Gıda A.Ş., are for our colleagues, customers, suppliers and solution providers.
It forms the framework of our responsibilities to our partners.
In this guide, Proteinocean Gıda A.Ş. will be referred to as “Proteinocean”.
1.4 Why Do We Follow a Code of Ethics?
Proteinocean conducts its activities and relationships with all its customers, suppliers and solution partners in accordance with the ethical values it has adopted.
undertakes to achieve.
The Proteinocean Code of Business Ethics was published to foster a robust and sustainable corporate culture. The Code will guide us on how to address ethical issues that may arise in our business processes and provide a common language for us to speak.
Proteinocean Business Ethics Rules are the responsibility of all Proteinocean employees in every position, our solution partners, business partners, company representatives, consultants, etc.
Our groups are expected to comply.
1.5 Responsibilities of Managers
Leading the implementation and enforcement of the Code of Business Ethics is among the primary responsibilities of our managers. In addition to setting an example by adhering to these rules, it is also our responsibility to ensure that our employees receive the necessary training on these ethics and to provide an environment and conditions that will enable employees to freely report any violations.
1.6 Responsibilities of Our Employees
We expect our employees to read, understand, and implement the rules contained in this guide. Furthermore, all employees are obligated to comply with all applicable policies, regulations, procedures, and guidelines within our company.
In matters that are unclear or cannot be resolved, the department manager, the Human Resources Department, or the Ethics Committee should be consulted before taking any action. Our employees are committed to ethical conduct.
They must actively participate in training regarding the rules.
Our employees who suspect or witness a violation of the rules are required to report the situation to the Ethics Committee as soon as possible.
1.7. Responsibilities of Our Solution Partners
As Proteinocean, we undertake to comply with the ethical rules we adhere to in our relations with all our stakeholders with whom we interact, and we also expect our stakeholders to comply with the same.
We are waiting.
2. ETHICAL RULES FOR EMPLOYEES AND EMPLOYEE CANDIDATES
2.1 Recruitment Process
At Proteinocean, we provide equal opportunity to candidates during recruitment. We do not discriminate based on factors such as race, color, gender, religion, language, marital status, sexual orientation, gender identity, political views, ethnicity, health status, family responsibilities, union activity or membership, physical disability, or age. Managers who make hiring decisions may not hire spouses, close relatives, or relatives of these individuals.
2.2 Working Conditions
Ensuring that our employees benefit from fundamental human rights and laws is always among our priorities.
Working hours, leave periods and rest periods are determined in accordance with the Labor Law and are regulated in detail in employment contracts.
Proteinocean's compensation policy is based on values that encourage sustainable success, based on fair, measurable, and balanced performance targets. Employees are not paid less than the minimum wage specified in the Labor Law.
While ensuring that our employees fully and correctly use their personal rights, we maintain a balance between work and private life.
We provide our employees with a healthy and safe work environment. Increasing employee loyalty and ensuring sustainable productivity are made possible through employee satisfaction. To this end, the Proteinocean Ethics Committee conducts regular employee satisfaction and loyalty evaluations throughout the year, and where necessary, adjustments are made.
improvement programs are being implemented.
2.3 Social Dialogue
All our employees work within predetermined teams, adhering to activity plans and workflow regulations. Our company's human resources representatives ensure effective dialogue between management and employees. All our business planning is organized to provide sustainable service to our customers within an effective oversight mechanism.
2.4. Education
We provide our employees with equal access to training. We ensure that employees receive training on the processes they operate, contributing to their performance. Training on codes of ethics ensures that our employees adhere to ethical values and act accordingly.
2.5 Diversity, Discrimination and Harassment
At Proteinocean, we value diversity, diverse perspectives, talents, and experiences, and we encourage this in our employees. Our employees are obligated to respect diversity in their dialogue with each other and our stakeholders.
We are committed to providing a fair, safe and healthy working environment for our employees, without discrimination based on factors such as race, color, gender, religion, language, marital status, sexual orientation, gender identity, political views, ethnic identity, health status, family responsibilities, union activity or membership, physical disability, age or pregnancy during recruitment, employment relations, discipline, promotion, salary determination, working hours, complaints and dismissal.
Physical, psychological violence, verbal harassment, or sexual abuse is strictly prohibited at our company. Our employees' private and family lives are respected. They are not forced to discuss private or sensitive matters with managers. Any violation of our employees' privacy through physical/psychological violence, sexual/emotional harassment, or harassment, whether at the workplace or anywhere else they are employed, is against both the law and ethical principles. No employee is permitted to be subjected to restrictions, interventions, coercion, or retaliation for reporting a violation or providing counseling or testimony. Systematic and planned behaviors intended to alienate the targeted individual from work, reduce their performance, or cause them to resign, which would be considered psychological harassment (mobbing), will not be tolerated.
3. BUSINESS ETHICS AND WORKING PRINCIPLES
3.1 Fighting Corruption and Bribery
At Proteinocean, we are committed to meeting standards of honesty and fairness in all our internal and external relationships, in accordance with national and international laws against corruption and bribery.
It is essential to comply with laws, regulations, and principles against all forms of bribery and corruption, and to avoid continuing business relationships with third parties (outsourced companies and business partners) who demand or offer bribes/corruption. Accepting, giving, or offering bribes, regardless of the purpose, is unacceptable.
No employee may receive benefits from, enter into private business relationships with, or request or make payments to third parties or organizations related to their work. All employees are obligated to comply with anti-corruption and anti-bribery rules and to report any violations to the relevant authorities.
3.2 Fair Competition
Proteinocean recognizes the importance of a competitive market and is committed to complying with all rules and regulations regarding competition and transparency, particularly Labor Law No. 4857 and Turkish Commercial Code No. 6102, in all our activities and operations. Our employees are responsible for complying with competition laws in all areas of our operations and not violating the intellectual property rights of third parties.
3.3 Conflict of Interest
A conflict of interest is a matter that can negatively impact the corporate identity and reputation. Proteinocean employees must avoid any conflict of interest and/or any other interests, whether their own or those of third parties. Situations that could give rise to a conflict of interest are listed below:
• Employees accepting money or providing benefits or advantages from third-party individuals or companies (current or potential competitor, customer, supplier, subcontractor or representative, etc.) that have a business relationship with Proteinocean,
• People who have family or up to third degree relatives have commercial relations with our company,
• Managers who have to make hiring decisions hire their spouses, close relatives and relatives of these individuals,
• Employees using their duties and authorities for personal and private gain for themselves, their families or third parties,
• Use of company assets, resources, facilities and personnel for personal benefit outside the company.
3.4 Gifts and Invitations
At Proteinocean, we prioritize maintaining professional relationships with third parties and ensuring they do not influence business decisions. Therefore, our employees are required to refrain from engaging in relationships with third parties, including customers, suppliers, and business partners, that could create a conflict of interest when offering or accepting gifts, invitations, or entertainment. The following rules are required of our employees in this regard:
• No gift should be accepted or offered that creates the impression of irregularity, that may cause or be perceived as a dependency relationship (providing privileges or references, ensuring the winning of a tender, etc.), except for gifts given in accordance with legal and commercial customs, traditions and traditions, or as souvenirs/promotional materials.
• With the knowledge of the management, appropriate products and services may be accepted as gifts and/or products or services that are compatible with the recipient's culture and ethical values may be given as gifts,
• In seminars and similar organizations attended on behalf of our company, gifts such as awards, plaques and similar gifts of symbolic value may be accepted as a memento of the day, in addition to cash.
• Promotional gifts and promotions approved by our company's management to our customers, suppliers and other third parties with whom we have business relations.
Gifts other than materials should not be given,
• Manager approval must be obtained for participation in invitations such as sporting events, domestic/international trips, etc. that are influential in decision-making or could be perceived as such, other than conferences, receptions, promotional events, seminars, etc. open to general participation organized by individuals or institutions with whom one has a business relationship.
3.5 Civil Society Organizations and Political Activities
Proteinocean approaches civil society organisations and political parties with the principles of integrity, honesty and impartiality.
Membership in any non-governmental organization and participation in its activities on behalf of Proteinocean may be undertaken with the knowledge of the management.
Proteinocean's resources may not be used to make in-kind or cash donations and/or support any political party or candidate. Propaganda, demonstrations, or similar activities are prohibited within the boundaries of any company-owned premises. Our employees must not engage in any political activities during working hours and must not take up the time of their colleagues in these activities. Our company respects the right of our employees to participate individually in political activities, provided they clearly state that they do not represent the company.
3.6 Information Security and KVKK
As Proteinocean, we consider information security to be among our top priorities and our company complies with the Information Security Rules and the Personal Data Protection Law (KVKK).
We act accordingly.
We are obligated to act with the understanding that our company's financial and trade secrets, employee rights and information, and agreements with our customers, suppliers, and business partners are subject to confidentiality. We are obligated to protect and maintain their confidentiality and not to share them with unauthorized individuals or authorities, both inside and outside the company. We are responsible for the data security of desktop and/or laptop computers entrusted to us, and we must use personal information we access for business purposes in accordance with the Personal Data Protection Law.
No one other than our company's senior management or authorized individuals may publish, interview, give statements, give conferences, or provide information about Proteinocean. Our employees must not share any confidential information related to our company's intellectual and industrial property rights with third parties. If sharing is necessary, they must take the necessary precautions to protect our rights in accordance with relevant procedures. Confidential files cannot be taken outside the company. Approval must be obtained from the person responsible for the information or senior management for confidential files or information that must be taken outside the company.
Passwords, user codes and similar identifying information used to access information about the company must be kept confidential and not shared with anyone other than authorized users.
Our employees must keep and archive records related to their work within the legal periods and must not respond to confidential information requests from third parties without the approval of senior management.
Proteinocean values the confidentiality of information belonging to its customers, suppliers, solution partners, and third parties with whom it has relationships. We must avoid knowingly and unauthorized unlawful use of our business partners' patents, copyrights, trade secrets, trademarks, computer programs, or other intellectual and industrial property rights. In keeping with the principles of fair competition, competitor information should be collected and used only from publicly available sources. The source of the information should be documented to ensure its legitimacy.
Our employees' salaries, fringe benefits, and other personal information are kept confidential and are not disclosed to anyone other than authorized personnel. Employee information is sent privately. Employees must not disclose this information to others, nor must they be pressured to disclose it.
4. Principles to be Applied in Case of Policy Violations
4.1 Ethical Violation Detection Assessment
If you have any questions about the principles outlined above, be sure to develop an action plan. Following the steps below and asking yourself these questions will guide you in deciding on an action plan, ensuring the system operates much more effectively. If you feel it's necessary, you can contact senior management.
A) Identifying the Event, Decision, or Problem
• Have you been asked to do something that you think might be wrong?
• Are you aware of a potentially illegal or unethical situation within our company or among your customers?
• Are you trying to make a decision and have doubts about how to act in accordance with business ethics?
B) Think Before You Decide
• Try to clearly define and summarize your problem or question.
• Ask yourself why there is a contradiction
• Consider options and consequences
• Consider who might be affected
C) Decide on a Plan of Action
• Determine your responsibilities
• Review all relevant facts and information
• Refer to our company policies, procedures and principles
• Assess risks and think about how you can reduce them
• Try to create the best action plan
D) Test Your Decision
• Review the ethical questions that need to be asked
• Review your decisions within the framework of the company's core values
• Make sure you comply with company policies, laws, and professional standards.
• Consult with qualification holders and consider their views within your planned action plan.
E) Continue with determination
• Share your decision with the relevant people along with your reasons. Share what you have learned.
• Share your success story with others
F) 4 Basic Questions to Consider
• Is this activity/behavior in accordance with laws, rules and customs?
• Is this activity/behavior balanced and fair? Would we be uncomfortable if someone else did it?
• Is there another course of action that would not create an ethical conflict?
• Who might be affected by this activity/behavior? Will there be a negative reflection on you or our company?
4.2 Dispute Resolution in Case of Violation
Those who violate the Code of Business Ethics or our Company's policies and procedures will be subject to various disciplinary sanctions, up to and including termination of employment. This policy is an integral part of and an annex to the employment contracts we have signed with our employees. Disciplinary sanctions will also apply to those who approve, direct, or have knowledge of inappropriate behavior or actions that violate the rules and fail to properly report them.
5. ETHICS BOARD
5.1 Board Members and Responsibility
The Ethics Committee is responsible for investigating and resolving complaints and reports of violations of the Code of Ethics. The Ethics Committee consists of individuals in the following positions:
* President – Chairman of the Board of Directors
* Member – Board Member
* Member – Human Resources Manager
If the person to whom the notification is made is a board member, the Chairman of the Board may appoint another person to the board instead of this person, if deemed necessary.
5.2 Ethics Committee Working Principles
The Ethics Committee carries out its work within the framework of the principles set out below:
• Keeps the identities of those making notifications and complaints confidential.
• Conducts the investigation as confidentially as possible.
• Has the authority to request information, documents, and evidence related to the investigation directly from the relevant unit. Any information and documents obtained may be examined only within the scope of the investigation.
• The investigation process is recorded in a written report from the outset. Information, evidence, and documents are added to the report.
• The minutes are signed by the chairman and members.
• The investigation is handled with urgency and the result is reached as quickly as possible.
• The decisions taken by the Board are implemented immediately.
• Relevant departments and authorities are informed about the results.
• While performing their duties on this matter, the chairman and members of the board act independently and without being influenced by the department managers to whom they are affiliated and the hierarchy within the organization.
• If deemed necessary, the Board may seek expert opinion and utilize experts by taking precautions that will not violate confidentiality principles during the investigation.
• The Board is responsible for the implementation and monitoring of the Business Ethics Rules and for making changes to other policies and articles it deems necessary.
5.3 Notification of Notice
At Proteinocean, we prioritize the sustainable implementation and adoption of our ethical principles to establish and maintain a culture of ethical behavior within our company. We guide our employees to report any identified or suspected violations of law, policy, or ethics in good faith, confidentially, and without facing any retaliation or victimization.
In this context, notifications to be made to the Ethics Committee;
* E-mail to be sent to info@proteinoceanlb.com
* Written submissions must be made in a sealed envelope to the address “Ostim OSB Mah.1268 cd. no:11 Yenimahalle/ANKARA” with the title “Proteinocean Ethics Committee”.