Internal and External Relationships

Internal and External Relationships

Relationships with Governmental and Public Bodies

The Company’s relationships with public administrations, political organizations, unions and other organizations must be based on the highest level of honesty, integrity, equality and independency.

Relationships with Customers, Suppliers and Other External Organizations

Our employees act in compliance with the principal of integrity in their relationships with customers, shareholders, affiliates and other firms on behalf of our Company.  

At Aydem Enerji, our main objective is to meet the needs of our customers. The level of customer satisfaction defines the success or failure of our Company, which is why our customers are the most important elements of our business. Ensuring customer satisfaction is the best advertisement we can possibly have. For this reason, customer relations management at the Company are based on the principles of professionalism, kindness, and above all, seriousness and reliability. Maximum level of honesty, equality and compliance with law must be maintained in customer relationships.  

Employees must provide customers with complete and clear information regarding the products and services offered by the Company. Employees are not authorized to give misinformation in order to gain higher profits. Our customers are clearly informed about their rights and liabilities in the activities they carry out with Aydem Enerji, and about the benefits and risks of the products and services offered to them. For this reason, our employees are obliged to be knowledgeable about both Aydem Enerji and the products and services offered by the Group Companies.  It is prohibited to use sales or communication techniques that are against the professional code of ethics, that give misinformation to the customer about the products and services, or that try to force the customer in the decision-making process.  

In addition to protecting the Company’s benefits from the activities carried out in the free market economy, employees avoid actions that may cause unfair competition based on the principles to ensure continuous trust in the energy sector, make efforts to improve the sector and work for joint interests. Employees, during the course of their duty, also do not express opinions or make comments -positive or negative- about competitors or their products and services.  

The above-stated rules also apply to the relationships with suppliers.  For relationships with persons or organizations from which we receive consultancy services, privacy conditions must be secured clearly with an agreement. On the other hand, an employee whose employment with the Company has been terminated can work at the Company for a temporary period as a consultant subject to a proposal by the manager of the relevant business unit followed by a review of the Human Resources Director and approval of the CEO.  

None of the Aydem Enerji employees can officially or unofficially make an actual or apparent commitment on behalf of Aydem Enerji without authorization according to the approved procedures, nor can they work with those who harm social ethics, the environment or public health.  

All Company employees must avoid all kinds of activities, practices and actions that are against the competition law, especially misuse of dominant position. Relevant rules are set out in the Competition Law Manual.  

Media Relations

In Aydem Enerji’s relationships with the press, our employees must avoid any act that may cause speculations or a negative opinion about our Company, and must refrain from practices and behaviors that may damage the reliability, reputation and consistency of our Company or the sector, or that may lead to unfair competition.  

Before the public and in areas where the audience thinks we are talking on behalf of the Company, we should not express our own opinions, but the Company’s opinions only.  Media relations for Aydem Enerji as a whole are handled by the Directorate of Corporate Communications. All external relations are maintained as per the procedures set out by the Company. All demands, interview requests and questions from print and verbal media must immediately be forwarded to the Corporate Communications Management Units at Aydem Enerji.  

For all contact details to be provided to third parties, prior approval must be obtained from the Directorate of Corporate Communications. Only authorized persons are allowed to engage in communications about the Company and the Company’s policies, practices and procedures.  

In posts shared on social media platforms, blogs, forums and emails, we avoid expressions that may cause third parties to assume that we are sharing the post on behalf of Aydem Enerji.  

The Aydem Enerji Digital and Social Media Principles Document is the basis for representing the corporate structure on social media.  

Conflicts of Interest

Aydem Enerji does not prevent their employees from engaging in external activities that will not cause them to neglect their internal responsibilities, that will not stop them from acting in line with the Company’s interests, and that are in compliance with our “Code of Ethics and Working Principles”. However, employees engaged in such activities must avoid possible or actual situations that cause conflicts between the Company’s interests and their own interests.

A “Conflict of Interest” arises when the personal interest of an employee and that of the Company affect/prevent each other. For example, an employee’s responsibilities or obligations that serve their own interests outside the Company or in their personal life may make it difficult for that employee to objectively/impartially and efficiently fulfill their responsibilities and tasks related to their job at the Company. A conflict of interest can also arise when one of the family members of an employee gains a personal benefit because of the employee’s position at the Company.

Any action or relation that may lead to a conflict of interest must be reported to the relevant Code of Ethics Consultant.

In order to prevent potential conflicts of interest, our employees:

• Avoid situations that would lead to an actual conflict of interest or the impression that there is a conflict of interest in favor of them or of the people related to them, and do not take part in the decision-making process for matters that are associated with their interests or that of the people related to them.
• Do not engage in any kind of personal financial relationship with the customers or suppliers, and do not use their business relations to gain personal benefits.
• Do not allow gift or benefit proposals that might affect their decisions or consent, or that might create a conflict of interest.
• Efficiently use the assets and resources of the Company only for the Company’s interests and benefits.
• Use their time and efforts for the Company, do not take on any other responsibility that would cause a conflict of interest, and do not work for another natural person or legal entity outside the Company.
• Comply with the principles of honesty and transparency, keep the required distance and maintain an unbiased attitude in their relationships with public bodies and institutes.
• Protect the secrets of the Company and the customers, and make sure that the Company’s proprietary information that would offer a competitive advantage is not taken out of the Company.  
• Do not use the information they have as per their jobs to get ill-gotten gains.  

Corporate Opportunities

When doing their jobs, employees from all levels must have the required common sense and make the necessary efforts, consider profitability and efficiency principles, and avoid all kinds of actions and operations that may cause loss to the Company. When there is an opportunity that will provide benefits for our Company, our employees are responsible for seizing such legal business opportunities.

Employees are not authorized to make decisions or carry out activities that are against the Company’s interests or not related to their responsibilities. In case of a potential conflict, the employee must immediately report the situation to the relevant Code of Ethics Consultant.

In case an opportunity arises for the benefit of Aydem Enerji as a result of the use of Aydem Enerji’s assets or information or through the relevant job position at the Company, the employee must avoid not using this opportunity because it is against their own interests, and avoid preventing other employees from using the opportunity.

Prohibition on Borrowing

Our employees can under no circumstances borrow money or gain benefits from or engage in a bailing relationship with customers or third parties during the course of or in relation to their duties.

Our employees must manage their personal and financial affairs in a responsible manner and must not go into debts that they cannot pay back. Our employees must have a balanced and consistent attitude with respect to their financial position both in their personal and professional lives.

While any debit/credit relationships are prohibited between the superiors-subordinates at the Company, employees also cannot be engaged in such a debit/credit relationship with the customers, suppliers and contractors.

Bribery

Bribery means directly or indirectly offering payments or interests to our employees to gain unlawful benefits or affect decisions and practices. Bribery can take many forms such as cash or non-cash payments, expensive gifts, offering the employee an advantage to serve their interests, etc.  When an employee is offered bribe by any person, company or organization, that employee must immediately report it to the relevant Code of Ethics Consultant.  

Political Activities

When fulfilling their duties, employees of the Company must not become members of political organizations using the Company’s name. In their personal memberships, on the other hand, they are obliged to avoid any activities that may harm the Company’s interests or reputation and adversely impact the working hours.  

None of our employees can engage in political resource management or campaign activities at the workplace or use the Company for such activities.  

Political Contributions

It is prohibited to make donations on behalf of Aydem Enerji (in cash or in any other way) to political parties, political organizations and the representatives and candidates of such groups, directly or indirectly, in order to gain advantages for the Company. Our employees must avoid situations that may imply monetary or moral support to political parties on behalf of Aydem Enerji.

Gift Acceptance

It is of great importance that the gifts sent to our employees due to their positions do not cause any suspicion in the eyes of third parties regarding the impartiality of our corporate judgements and decisions. Preventing inappropriate relationships with third parties that may harm the reputation of Aydem Enerji is only possible through a corporate approach and implementation with regards to gift acceptance. For this reason, our employees must follow the rules below when it comes to accepting gifts.

Our employees cannot request or accept an object/service that is above the nominal value (100 USD) for any transaction or business, or cannot request or accept cash, check, etc. of any value.

Same rules apply even if the person does not gain a direct advantage from this valuable object. Similarly, it is not allowed to accept something valuable on behalf of a third person or party.

Our employees must not accept or request gifts, entertainment or other offerings that may or aim to affect the preferences and decisions of our Company.

An employee who received a gift that is not in compliance with the rules above must inform their manager and return the gift to the person or organization who sent it. In cases where one cannot be sure if the gift is appropriate or not, a written approval must be obtained from the relevant Code of Ethics Consultant.

If it is determined that returning a gift with a value above 100 USD is not practical or may lead to a situation that is not desirable in terms of the business relationship in question, acceptance and use of the said gift is only possible upon written approval by the relevant Code of Ethics Consultant. In such cases, acceptance of the gift must at the same time (e.g. within 24 hours) be reported to the Directorate of Internal Audit and Control.

All gifts that have a value at or above 100 USD must be recorded by the Management, and the gift acceptance reports created must be stored by the Managers to be submitted to the Code of Ethics Consultant when necessary.

Furthermore, in order to prevent the relevant organization from sending similar gifts in the future, a thank you letter could be sent to them, explaining the principles and practices of our Company in this regard.

All employees are obliged to follow the procedures above and report any actual or suspected situation that is against these procedures to the relevant Code of Ethics Consultant and the Human Resources Management.

Offering Gifts and Donations

Gifts can be offered to customers, business partners or supplier representatives on behalf of the Company in order to maintain the business relationship. However, no matter what their value is, gifts must be of a nature that does not impact any decisions to be made within the scope of the principle of honesty and business relationships.  

The process must comply with the principles set out by the Aydem Enerji management and the general practices and must not damage the reputation of the Company. Principles regarding acceptance of gifts, invitations and donations are also valid in the process of offering them, and the 100 USD limit will apply.  

Acceptance of Activities Where Third Parties Are Sponsors or Cover the Expenses 

Our employees must not accept entertainment, free training, seminars, accommodation, trips, meals, etc. that are aimed at influencing their business decisions.  

However, the Company agrees that rejecting such offers in certain cases may harm the relationships with customers. For this reason, any free of charge offers that third parties or existing or potential customers make to our employees to attend a conference, promotional meeting, training, etc. can be accepted only upon written approval by the top executive of the relevant function and the relevant Code of Ethics Consultant.