TRIO Entegrasyon Code of Ethics and Business Conduct

1. Introduction

At TRIO Entegrasyon, we are committed to maintaining the highest standards of integrity and ethical conduct. This Code of Ethics and Business Conduct outlines the principles that guide our business practices and interactions with stakeholders.

2. Core Values

• Integrity: We act with honesty and integrity in all our dealings.
• Respect: We treat everyone with respect and dignity.
• Excellence: We strive for excellence in everything we do.
• Innovation: We encourage creativity and innovation to drive progress.
• Responsibility: We are accountable for our actions and their impact on society and the environment.

3. Antitrust and Competition

We are committed to fair competition and complying with all antitrust laws and regulations. Employees must:

• Avoid Anti-Competitive Practices: Refrain from engaging in agreements or practices that unfairly restrict competition, such as price-fixing, market allocation, or bid-rigging.
• Maintain Independent Judgment: Make business decisions based on independent judgment and avoid discussions with competitors regarding prices, terms, or market strategies.
• Report Concerns: Report any suspected anti-competitive behavior or practices to the appropriate internal authority or regulatory body.

4. Improper Payments

Our organization prohibits any form of bribery or corruption. Employees must:

• Prohibit Bribes and Kickbacks: Do not offer, give, or accept bribes, kickbacks, or any other form of improper payment to influence business decisions or gain an unfair advantage.
• Follow Reporting Procedures: Report any suspected improper payments or unethical conduct immediately through the designated channels.
• Comply with Anti-Corruption Laws: Adhere to all applicable anti-corruption laws and regulations, including those governing interactions with public officials.

5. Money Laundering

We are committed to preventing money laundering and other financial crimes. Employees must:

• Avoid Money Laundering Activities: Do not engage in, or assist others with, activities that may involve the laundering of money or financing of terrorism.
• Know Your Customer: Ensure that all financial transactions are transparent and comply with applicable laws, and verify the identity of clients and counterparties as required.
• Report Suspicious Activities: Report any suspicious financial transactions or activities that may indicate money laundering to the appropriate authorities.

6. Economic Boycotts

We do not participate in or support any form of illegal economic boycotts. Employees must:

• Adhere to Legal Restrictions: Ensure compliance with all relevant laws and regulations regarding economic boycotts, including those imposed by governments or international bodies.
• Avoid Unlawful Boycotts: Do not engage in, or support, any boycotts or restrictive trade practices that are not legally sanctioned or that violate trade regulations.

7. Dealing with Government

When interacting with government officials and agencies, employees must:

• Ensure Transparency and Integrity: Conduct all interactions with honesty and integrity, and avoid any actions that could be perceived as unethical or improper.
• Comply with Regulations: Follow all applicable laws and regulations governing interactions with government entities, including procurement and contracting rules.
• Report Irregularities: Report any irregularities or concerns related to dealings with government officials to the appropriate internal authority.

8. Lobbying of Government Officials

Our organization supports ethical lobbying practices. Employees must:

• Register and Disclose Lobbying Activities: Ensure that all lobbying activities are properly registered and disclosed as required by law. Follow all relevant regulations governing lobbying efforts.
• Avoid Unethical Influence: Do not offer or promise anything of value to government officials to gain favorable treatment or influence decisions.
• Act Transparently: Conduct all lobbying activities in a transparent manner, clearly identifying the organization’s position and interests.

9. Trade Compliance Laws and Regulations

We are committed to complying with all trade laws and regulations. Employees must:

• Adhere to Trade Regulations: Follow all applicable laws and regulations related to international trade, including import and export controls, customs regulations, and sanctions.
• Ensure Accurate Documentation: Maintain accurate records and documentation for all international transactions and trade activities.
• Report Non-Compliance: Report any instances of non-compliance with trade regulations to the appropriate authorities or internal compliance officers.

10. Compliance with Laws and Regulations

We comply with all applicable laws, regulations, and industry standards. Employees are expected to understand and adhere to the legal requirements relevant to their roles.

11. Fair Business Practices

• Anti-Corruption: We prohibit all forms of bribery and corruption.
• Fair Competition: We compete fairly and do not engage in anti-competitive practices.
• Confidentiality: We protect confidential information and respect the privacy of our stakeholders.

12. Workplace Conduct

• Non-Discrimination: We provide equal opportunities and do not tolerate discrimination or harassment.
• Health and Safety: We are committed to providing a safe and healthy work environment.
• Professionalism: We expect employees to conduct themselves professionally and uphold the company’s reputation.

13. Conflict of Interest

Employees must avoid situations where personal interests conflict with the interests of the company. Any potential conflicts should be disclosed to management.

14. Environmental Responsibility

We are dedicated to sustainable practices and minimizing our environmental footprint. We encourage employees to support and participate in environmental initiatives.

15. Reporting and Accountability

Employees are encouraged to report any unethical behavior or violations of this Code. We ensure that reports are handled confidentially and without retaliation.

16. Implementation and Review

This Code is reviewed regularly to ensure its relevance and effectiveness. Employees are required to acknowledge their understanding and commitment to this Code.