1.1. Ethical Practices
This section outlines Mazaka’s high ethical standards and practices across a wide range of our activities and policies, including lawful business transactions, the proper use of insider information, and the prevention of corruption. These are designed to protect our reputation and ensure the highest standards of integrity in all our internal and external operations.
12.2.1. Lawful Business Transactions
• Mazaka personnel and the company will act in full compliance with all laws and regulations in the countries in which they operate, and will protect the company’s reputation for ethical conduct and financial integrity. • Mazaka personnel must be aware of, update their knowledge of, and comply with all laws, rules, and regulations relevant to their field of work.
12.2.2. Policy Regarding the Use of Insider Information
• It is Mazaka’s policy to ensure that insider information remains confidential and is used and/or shared appropriately. • All Mazaka personnel shall keep all information about the Company confidential and/or internal to the Company, except where disclosure is necessary for the conduct of Company operations. • Mazaka personnel may not disclose confidential and/or internal Company information for the purpose of directly or indirectly benefiting themselves or others, regardless of whether any benefit is obtained. • Mazaka personnel may not sell, buy, transfer, or acquire Company securities using confidential and/or internal Company information; and/or conduct any transaction using confidential and/or internal Company information in a way that could directly or indirectly harm the Company. This provision also applies to the spouses and children (minors) of Mazaka personnel. Those who violate these regulations will be considered to have committed a serious offence. • Mazaka will treat personal data for which consent has been given for collection, storage, use, and disclosure as Confidential Information.
12.2.3. Anti-Corruption Policy
• Preventing bribery and corruption is Mazaka's policy to ensure that its business operations are conducted ethically. • This policy also applies to those authorized to act on behalf of or represent the Company.
• It also applies to Stakeholders.
• This policy is intended to supplement any local anti-bribery and corruption laws and regulations that operate or will operate.
12.2.3.1. Bribery
The Company expressly prohibits any act of Bribery, including making, promising, or offering to make any payment or gift, directly or indirectly, to an institution, business partner, public official, political party, or any third party for the purpose of corrupting the improper performance of transactions, duties, or decisions.
12.2.3.2. Gifts and Hospitality
The Company recognizes that different cultures have different perspectives on gifts and hospitality. Mazaka allows each of its businesses to establish appropriate guidelines and limits regarding the giving or receiving of gifts and hospitality, provided that such acts are in accordance with local customs and are not for the purpose of obtaining an illegal service or in exchange for an illegal service. In such limited circumstances, offering or accepting hospitality may rarely be permitted within a business relationship. However, each business will monitor compliance to prevent inappropriate or illegal gifts and hospitality. Employees must inform their department managers before offering or accepting any hospitality. In case of doubt, employees should consult their department managers before promising any gifts or offering hospitality. The value of gifts given or received and/or hospitality expenses should not exceed 20,000 TL.
12.2.3.3. Charity and Humanitarian Aid and Sponsorships
While charity and humanitarian aid and sponsorships constitute a significant part of the Company's corporate social responsibility, it is possible for them to be misused or used to conceal illegal activities. Appropriate background checks should be conducted with all charities and humanitarian organizations before making any donations.
12.3. Fair Business Practices
This section governs the conduct and policies designed to protect our assets and businesses. It includes policies for managing conflicts of interest and preventing the loss of Mazaka’s intellectual property, and ensures we maintain a high level of trust among all our internal and external stakeholders.
12.3.1. Conflict of Interest
• Mazaka personnel must always act in the best interests of the company. • Mazaka personnel must not place themselves or their relatives in positions where their interests or the interests of their relatives may directly or indirectly conflict with the interests of the company.