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ETHICAL PRINCIPALS POLICY

LOGISTICS OF THE FUTURE
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ETHICAL PRINCIPALS POLICY

The Ethical Principals Policy covers all employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. A substantial part of policy items defines the technical behavior principles not only in the office but also outside the office. If the employees have any hesitation/problem related to special aspects which are not mentioned in the policy, they shall refer to regulations, policies and procedures specific to subject, if any, but if there is no such a regulation, policy and procedure, they shall receive the opinion of their managers.

The Ethics Principles of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti are defined within the hierarchy of common values, principles and rules. Act within the light of ethical principles and values in cases not defined in the section of rules and act within the direction of common values in cases not defined within principles. In case of any hesitation related to implementation of ethical principles, each employee is encouraged and requested to receive the opinion of his/her department manager and senior manager, if necessary.

Our Common Values

Our common ethical values constitute the principles of our interaction with our customers, each other and public and one of building blocks of common culture of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. Our main values which lead making the ethically correct thing and fulfilling our responsibilities against our customers, each other and public, are as follows:

Honesty

To endeavor to offer the superior service possible to our customers and public and strengthen and maintain the feeling of respect and courtesy to each other and support environment

Our Ethical Principles

Our common values are supported with 7 ethical principles. These principles also form a basis for our ethical rules. Our corporate ethical principles are as follows:

Honesty – We are honest in our behaviors and communication.

We act honestly in our internal and external relationships

We convey clear and accurate information to our customers in terms of quality of service that we can produce and offer and experience and competency we have.

Confidentiality – We respect the confidentiality of customer data, corporate data and employee data of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.

• We maintain the confidentiality of customer data against the persons who don’t have right to access them legally, and persons other than the employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.
• We don’t abuse data of our customers, institution and workmates for benefit of our personal interests or third parties.

Competency – We ensure the competency and devotion necessary for offering our services at expected level.

• We are aware that our customers (and customers of our customers indirectly) expect high standard services from us in our field of activity.
• We pay necessary attention to appoint employees with competencies in conformity with the requirements of task for fulfilling the expected service quality and to increase the competency of our employees continuously.

Accountability to Public – We are aware of significance of our services on commercial life in respect of activity of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.

• We are aware of our role in the social life and energy sector and we take all necessary precautions not to give an intended and unintended damage. We try to build our staff to increase the social benefit.

Compliance with Laws and Protecting the Corporate Reputation – We act in conformity with the applicable laws and occupational principals and protect the corporate reputation.

• We conduct activity in conformity with the laws, regulations and occupational principles applicable in our field of activity.
• We avoid from behaviors which may damage the reputation of our institution and customers.

Fair Behavior in conformity with Courtesy Rules - We behave fair in a respectful manner to each other and maintain our support environment.

• We behave accountably within the frame of respect and courtesy rules by being aware of impact of our individual social behaviors on our institution, colleagues and public.
• We behave respectfully and fairly to each other. Our promotion and wage policy are based on merit and equal opportunity for everyone.

Serving as a Model within the direction of Common Values – We act in a manner that we will serve as a role model for our workmates within the direction of our common values.

• We are aware of being in a critical and risky commercial activity in which ethical behavior has a major importance.
• We pay attention to take decrees in conformity with our common ethical values in our daily behaviors, mid and long-term decrees, and expect other colleagues to act in this manner. In case of hesitation, we consult our managers.

Our Ethical Rules

While our ethical rules are defined within the direction of abovementioned values and principles, it is possible to cover each situation. Considering this fact, the employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. shall ask the below-mentioned questions themselves in order to determine the right behavior in cases not defined in this policy:

• Are my acts contrary to law or ethical values and principles of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.?
• Am I honest and fair?
• Do I feel a need for hiding my planned act from my family, friends and colleagues or feel ashamed if I told it to them?
• Is the reputation of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. damaged if my act is disclosed at newspapers?
• Do I feel any personal discomfort concerning my planned act?
• Does my behavior put the life, health, safety or reputation of any person at risk?

If you have any hesitation following these questions, you shall consult and receive opinion of managers and senior management, if necessary. As stated among ethical rules, the consulting culture have a major importance in the implementation of ethical principles. The verbal communication can be established for receiving opinion, but the written communication shall be preferred for taking under record.

Our ethical rules are grouped under the titles of our responsibilities towards our customers, each other, public and social media.

Our Responsibilities towards Our Customers

Data Confidentiality

ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. directs and processes it customers’ data as a requirement of its field of activity. The access to these data and statistical information is made by only employees who need to access hem by virtue of their duties.

Since almost all this information is specific to our customers and confidential, our employees who have access to them as a part of their duties, are liable for keeping them confidential. The employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. cannot use the personal data of our customers, third parties that ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. offer service, and other persons and institutions that they may access during their duties, with the aim of gaining advantage for themselves or other parties. The written and verbal communication of confidential information even within the office of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. shall be limited to employees who need to access them by virtue of their duties. The necessary attention shall be paid to ensure that the confidential information is not heard by people around during verbal communication.

The new solutions and service needs, new industry standards and best practices and technological trends in sector and components constituting the corporate infrastructure shall be followed in order to enhance our services and increase the service quality. The competent employees shall be appointed to relevant roles and technical and managerial development of employees shall be ensured to meet the expected service quality. The appointed employee shall pay the care required by his/her duty.

Relationships with Product and Service Providers

The quality of service that ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. offers to its customers, depends on developing efficient relationships based on honesty with service providers at a specific level, ethical behavior and mutual trust. The product and service providers are preferred based on the quality of product or service offered, price, delivery and support conditions. The decisions of buying and election are taken based on job requirements and objective selection criteria.

Our Responsibilities towards Each Other

Honesty and Trust, Respect, Courtesy and Fair Behavior

As employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti., we shall act in conformity with honesty, respect, courtesy and fair behavior principles in our relationships and fulfilling our responsibilities towards each other. Each of us is responsible for carrying out the works required by our position at necessary quality and fully. We shall be aware that the best working environment is a working environment in which the mutual trust and support environment is created and maintained. Any kind of discrimination, verbal or physical harassment and outrageous behaviors are not expected from any employee of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.

Consulting Culture

ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. supports a working environment based on consultancy principles with the aim of minimizing all kinds of technical and managerial faults. Consulting about non-routine or emerging problems are not only supported but also expected. Both the managers and their employees are expected to consult and exchange views with their managers. ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. has adopted confronting third parties on technical and other issues as single voice by operating the in-house consulting process with the aim of preventing the potential misunderstandings and unnecessary risks.

Conflict of Interests

The employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. continuously take business decrees as a part of their jobs. The employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. are liable for avoiding for making decisions from situations contrary to ethical principles and law, which may give a rise to conflict between their interests and personal or third parties’ interests. When taking business decisions, the employees shall prioritize the interests of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. over their own interests. Although it is difficulty to develop a list consisting each situation related to conflict of interests, the examples are as follows:

• Being a partner or employee of a company, which supplies product or service to ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. or undertaking these roles non-officially.
• Dealing with another job/role which may lead to hinder the duty of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.
• Providing unjust advantage to relatives or acquaintances.

Personal Relationships

A romantic or normal friendship can sometimes be made between two employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. or one of its employee and employee of an institution to whom/from which service is offered or taken. Such relationships can lead to conflict of interests apparently or essentially. Although ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. regards such relationships normal, it does not support the cases which may damage the independency and lead to conflict of interest apparently or essentially.

Use of Information Systems and Other Assets of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.

The information systems and other assets of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. belong to institution and they shall be primarily used as a part of job. Each employee of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. is liable for protecting the assets of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. and using them efficiently.

The personal use of assets shall be only done at minimum level, if necessary and in a manner that will not hinder the activities of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. and thus, the assets shall not be used in contrary to the laws or ethical principles. The employees shall obtain consent from his/her manager if the cost of personal data use (monetarily and/or timely) exceeds the minimum level. If there is a hesitation concerning whether the cost is significant or not, the manager shall be consulted as required by consulting culture.

Our Responsibilities Towards Society

Compliance with Laws and Cooperation with Other Institutions

The employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. shall act in conformity with all applicable legal regulations and laws. Our aim is not only to act in compliance with laws but also ethical principles in our activities. ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. makes cooperation with law enforcement officers within the frame of defined protocols.

Information Disclosure

The employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. shall pay attention not to disclose the corporate and personal data to press or other parties during their daily or official conversations. While ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. adopts clarity and honesty principle in its communication, they are liable for assessing the impact of disclosure of confidential information on customers of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. and society if they are disclosed.

Fighting Against Bribery and Corruption

Pursuant to the anti-bribery and anti-corruption policies and procedures of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti.:

• All employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. knows that offering and accepting bribery or giving bribery directly or indirectly during their activities is forbidden.
• The inconvenient interests such as gift or commission are forbidden.
• The prior consent shall be obtained for political aids, charitable contributions and sponsorships.
• The offer and acceptance of gift, hosting expenses and other expenses are kept under supervision.
• All financial transactions are recorded in accounting records and accounts properly and clearly.

If any employee of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. offers or accepts any type of bribe directly or indirectly (money, gift, other interests) when fulfilling his/her duties within the body of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. or s/he is convinced to do something which should not be done, or not to do something which should be done, this means the breach of policies of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. and it is a criminal offence.

If any employee of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. promise or offer or accepts any type of bribe directly or indirectly (money, gift, other interests) when fulfilling his/her duties within the body of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. with the aim of convincing another person to do something or not to do something by virtue of his/her role and position when fulfilling his/her duties, this means the breach of policies of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. and it is a criminal offence.

All employees of ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. is obliged to comply with this policy and laws strictly.

ITT Uluslararası Taşımacılık San. Tic. Ltd. Sti. fully undertakes to prevent all kinds of bribe and corruption in every country where it carries out activity, and to follow the applicable national and international anti-bribery and anti-corruption laws in all its legal spans of authority where it is situated, or it offers service.