Ethics and Compliance

Ethics and Compliance

We accept integrity, honesty, justice and observance of rights as our basic principles in all our activities. In addition to complying with the laws of the countries in which we operate, we also consider respecting people, the environment, society, traditions and customs as a requirement of our business culture. The rules of business ethics that we adopt as core values determine the behavioral standards of all our employees and stakeholders and guide our relationships to operate within the framework of honesty and integrity.

It is the primary responsibility of all employees to ensure that the name of the brands owned by Eralp Kimya and our group companies is associated with trust, honesty and professionalism and to take it further. In this regard, the expectations from our employees at Eralp Kimya and group companies are listed below:

1.1 Code of Ethical Conduct That Employees Must Follow

  • Always comply with the laws,
  • To fulfill their duties within the framework of basic moral and human values,
  • To act fairly, in good faith and with understanding in order to achieve mutual benefit in all relationships,
  • Not to take unfair advantage of persons or organizations for any purpose, not to accept or give bribes, to prevent such actions to the extent of knowledge, and to act in accordance with the anti-corruption rules;
  • To act in accordance with the relevant business ethics rules and all the application principles that support these rules in ongoing duties, and in this context, not to behave in a way that would prevent other employees from performing their jobs properly and not to disrupt business harmony.
  • Not to engage in any behavior, statement or correspondence that would put the company under commitment unless expressly authorized,
  • To take care of all tangible and intangible assets of the company, including its information and information systems, as if it were its personal property, and to protect them against possible loss, damage, misuse, abuse, theft and sabotage,
  • Not to use working time and company resources, directly or indirectly, for personal gain and/or political activities and interests, whether of monetary value or not,
  • To keep the wages, wage add-ons and the arrangements to be made over time confidential, not to share them with unauthorized persons and authorities inside and outside the institution, and not to use them for speculative purposes in a way that would disrupt the working peace.

 2.1 Information Security

 All company regulations, commitments and regulations regarding information security and confidentiality are considered as complementary to the following items.

2.1.1 Intellectual Property Rights

  • To ensure that legal procedures are initiated and completed on time in order to secure the intellectual property rights of newly developed products, processes and software, and to prevent such inventions and information from being shared with third parties without written approval,
  • Avoiding the unlawful – knowing – unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies,
  • To take the necessary measures in accordance with the relevant procedures to protect our rights in cases where confidential information regarding all kinds of intellectual and industrial property rights of our company needs to be shared with third parties.

2.1.2 Information Management

  • To ensure that all records are kept and archived in a healthy manner within the legal period,
  • Not responding to requests for information from third parties that are classified as confidential for the company without the approval of senior management,
  • To show the necessary care to ensure that the statements made and reports presented by the company are truthful.

2.1.3 Security and Crisis Management

  • To take necessary precautions and ensure communication to protect company employees, information and information systems, business and administrative areas against possible terrorism, natural disasters and malicious attempts,
  • Terrorism, natural disaster etc. To make the necessary crisis planning regarding emergency crisis management in case of a crisis, thus ensuring the continuity of the business with minimum loss in case of crisis,
  • To take all precautions to prevent theft or damage to company assets.

 2.1.4 Privacy

  • To act with the awareness that the financial and commercial secrets of Eralp Kimya and its group companies, information that will weaken the competitiveness of the companies, employee rights and information, and agreements with business partners are within the framework of “confidentiality”, and to ensure their protection and confidentiality,
  • Not to share the information learned and the documents they have for any purpose with unauthorized persons and authorities within or outside the institution, and not to use them for speculative purposes (directly or indirectly),
  • Not to use non-public information about the companies they work for, their customers and other persons and companies with whom they do business, for purposes other than the intended purpose, and not to share it with third parties without obtaining the necessary permissions.

2.1.5 Social Media Use

  • It is prohibited to share information about the company on any platform, including social media channels, public forums, personal blogs, social media accounts, on the web and mobile applications that are not provided or controlled by the company.

2.2 Avoiding Conflicts of Interest


  • Conflict of interest; It refers to all kinds of benefits provided to employees, their relatives, friends or persons or organizations with whom they have a relationship, and the situation in which they have any financial or personal interest related to them, which affects or may affect the employees’ ability to perform their duties impartially.

2.2.1 Not taking action in favor of oneself or relatives

Not to take unfair advantage of himself, his relatives or third parties by taking advantage of his title and authority,

  • Not to take unfair advantage of himself, his relatives or third parties by taking advantage of his title and authority,
  • To be careful not to have a conflict of interest with the current institution in personal investments,
  • To take care that personal investments or pursuits other than any business activity do not interfere with the ongoing work of Eralp Kimya and its group companies in terms of giving time and attention, and to avoid such situations that prevent focusing on main duties.
  • The status of superior is prohibited if the employee and the person in the primary decision-making position regarding the same job in the company, which is the customer or supplier, are first-degree relatives.
  • If it is learned that relatives have shares or financial interests in another company with which they have commercial relations, it is mandatory to inform the superior.

2.2.2 Participation in representation and organization invitations

Open to general participation by individuals or institutions with which we have or have the potential to have business relationships; conferences, receptions, promotional events, seminars, etc. sports activities, domestic/international trips, etc. that affect decision-making or may be perceived as such. Participation in invitations is subject to the approval of the General Manager.

2.2.3 Leavers Doing Business with the Group

Establishing a company yourself or becoming a partner in another company after leaving your job in the company and doing business as a salesman, contractor, consultant or similar to Eralp Kimya and its group companies is a very important issue that should be taken into consideration as it may create a negative perception. It is also important to pay attention to the fact that an employee who leaves the company is in a senior management or decision-making position in another company.

  • Before or after such a process, it is necessary to act within the framework of the Company’s interests, comply with moral and ethical rules, and not allow conflicts of interest before and after the process.
  • In case of re-employment of an employee who has left the company, the condition is that his/her employment has not been terminated due to non-compliance with any of the principles specified in the Code of Ethical Conduct and Implementation Principles.

2.2.4 Sharing and Trading of Inside Information (Insider Trading)

It is a legal crime to attempt to obtain any commercial benefit (insider trading), including directly or indirectly buying and selling shares on stock exchanges, by using any commercial, financial, technical and legal etc. confidential information belonging to Eralp Kimya and its group companies or by giving it to third parties. to know and certainly not to attempt.

  • To take the necessary measures to protect confidentiality even after leaving the company and to comply with the Information Security Commitment.

2.3 Fighting Corruption

Eralp Kimya and its group companies are against bribery and all kinds of corruption. Corruption harms business life, institutions and their employees, and irreparably damages business reputation and reputation. Eralp Kimya and its group companies are extremely meticulous and sensitive in the fight against bribery and corruption. All employees and all third parties acting on behalf of the company are obliged to comply with anti-corruption rules and relevant legislation.

2.3.1 Receiving and Giving Gifts

Eralp Kimya and its group companies, in principle, prohibit all its employees from entering into relationships with all third parties, including customers, suppliers, dealers, authorized dealers and authorized services, that may create the impression of gaining financial benefit, including offering and accepting gifts, invitations and entertainment.

The following criteria must be followed in the conduct of relations with private or public persons and organizations that wish to establish or maintain business relations with Eralp Kimya and its group companies;

  • Any gift, other than materials given in accordance with legal and commercial traditions, customs and traditions, or souvenir/promotional materials, that creates the impression of an irregularity, may cause a relationship of dependency, or may be perceived as such (providing a privilege or reference, causing a tender to be won, etc.). should not be accepted or offered.
  • Gifts should never be given in cash or in a form convertible into cash (such as a gift voucher).
  • No discounts or benefits that may be perceived as inappropriate should be requested from suppliers, customers or third parties, should not be offered to third parties and/or should not be accepted when offered.

2.3.2 Fighting Bribery and Corruption

No form of bribery or corruption is tolerated at Eralp Kimya and its group companies. It strictly complies with the anti-bribery and anti-corruption laws and regulations that apply wherever we conduct commercial activities, and expects its employees to comply in the same way.

  • All payments to suppliers, consultants etc. to other parties must be tied to the service/products and not to anything that could be construed as a bribe.
  • Employees of Eralp Kimya and its group companies and persons/institutions/organizations doing business on behalf of the company should not offer, give or receive any gifts, gratuities, entertainment or other benefits that are believed to affect public or commercial decisions or cause improper performance of a public/commercial activity.
  • All of our employees are obliged to report any suspicions or allegations regarding any case detailed in Article 2 (Article 5 will guide you if you have doubts about how to proceed).

3. Occupational Health and Safety

Our group aims to fully ensure occupational health and safety in the workplace and on the job. Employees act in accordance with the rules and instructions set for this purpose and take the necessary precautions. They adopt the principle that occupational health and safety improvement activities are the common responsibility of all employees,

  • Employees will not keep any items or substances that pose a danger to the workplace and/or workers or are illegal, in the workplace.
  • Employees; Except for those that are kept based on a valid doctor’s report, they will not keep drugs, addictive substances, or substances that restrict or eliminate mental or physical faculties in the workplace, and they will not work in the workplace or within the scope of work while under the influence of such substances.

4. Non-Governmental Organizations and Political Activity


Employees must stay away from situations that may create a conflict of interest in their current duties and responsibilities due to the political activities in which they are involved.

  • The company name, title within the company and company resources cannot be used in political activities carried out individually.
  • Political propaganda cannot be made during working hours and the workplace environment, employees cannot be asked to become members of a political party in any way, and other employees’ time cannot be taken for these activities.

Membership in any non-governmental organization and participation in its activities on behalf of the Company can be done with the knowledge of the Company.


5. Code of Ethical Conduct Implementation Principles


Obligation to Notify Violations and Report a Concern

Eralp Kimya and its group companies attach importance to open and transparent communication. Our companies have an Ethics Line so that our employees can report transactions and behaviors that they believe violate Eralp Kimya company policies and procedures. Notification can be made to Ethics Line via e-mail ( /

When such concerns arise, employees are advised to first consult their immediate superiors before contacting the Ethics Line, but in cases where their concerns are not resolved in this way, employees will be able to reach the Ethics Committee, the authorized unit of Eralp Kimya, through the Ethics Line.

Disclosure of any notification made by the person in a way that would negatively affect the peace in the workplace or business relations to third parties will be strictly prevented.

  • It is not allowed to threaten, retaliate against, or harm any employee in any way, whether in or outside the workplace, of any employee who refuses to act contrary to ethical rules and makes a report in good faith. Such behavior is interpreted as a violation of ethical rules and necessary disciplinary penalties are applied.
  • It is very important that the person making the notification is free from any intention such as gossiping about the person reported to him or trying to negatively affect his career. In this regard, confidentiality, objectivity and compliance with ethical rules are extremely critical issues during the reporting and investigation process. It is mandatory for those who both make the notification and manage the process to pay utmost attention and attention to this issue.
  • When deliberate false and/or slanderous statements are detected, they are interpreted as a violation of ethical rules and necessary disciplinary penalties are applied.
  • The management primarily provides assurance to ensure the appropriate environment and effectiveness of the notification mechanism. Employees are made aware to support the management in ensuring the effectiveness of the notification mechanism.

Some of the types of violations or inappropriate behavior that may be reported include:

  • Environmental, health and safety issues
  • Workplace disputes and misconduct
  • Situations where information protection and data confidentiality are violated
  • Threats and physical violence
  • Practices contrary to internal and external legislation
  • Human rights and employee rights problems and/or suspected violations
  • Criminal elements that can be considered as bribery, corruption and abuse of security
  • Providing unfair and personal benefit
  • Leakage of confidential information (within the scope of trade secret; such as contracts, patents, project information, tender price information, product prices and costs that have not yet been announced, company financial data and tables, customer and vendor information, personal data about employees)
  • Managers’ use of employees for private business
  • Being unfair in performance evaluation
  • Lack of equal treatment of employees
  • Neglect and abuse of duty