• To comply with legal obligations, standard conditions of the management systems set in our company, and ethical conducts; consider the needs and expectations of the concerning parties, meet the related expectations and requirements to the extent of their applicability,
• To contribute the economy of the country and religion, and increase our market share by presenting quality and environment-friendly sustainable products with the life cycle perspective,
• To become a reliable and preferred brand in the sector by continuously improvising our product and service quality, and ensure the continuity of our quality,
• To carry out hygienic, quality manufacturing with maintained authenticity in compliance with food and animal food safety conditions at every stage of our Sodium Carbonate and Sodium Bicarbonate production,
• To timely and fully meet the customer requests to maximize the customer satisfaction,
• To meet the training need of our employees, contribute their personal development, increase employee satisfaction, create tem spirit in our employees to ensure the achievement of unit and company goals, to increase awareness of our employees regarding quality, environment and occupational health,
• To provide the necessary open communication environment to encourage the participation of employees and employee representatives,
• To make our suppliers embrace our management systems for them to improve their product and service quality,
• Exercise strategic approach and provide leadership in effective management of the resources and in issues such as sectoral innovation, technologic development etc. which are important for our company,
• To take measure to minimize the effects harmful for human health end environment, prevent environmental pollution and climate change sourced from our operations, evaluate risks that may cause occupational diseases and accidents and eliminate these risks, achive the final goal of “Zero Environment and Work Accident” by continuously improving the working conditions,
• Within the scope of “preventing orminimizing waste generation”, which forms the basis of the zero waste management principle, to collect the wastes separately at their source and to ensure their recovery,
• To share our policies with our customers, suppliers, employees and the local people, and be in an effective communication and collaboration.
Purpose of the Policy
Modern slavery is a fundamental violation of human rights and must be struggled globally. The modern slavery term includes slavery, servitude, forced and compulsory labor, bonded labor, child labor, and human trafficking crimes. Although these crimes seem similar, they are legally different from each other.
Slavery:Having to work without an affordable payment or appreciation.
Servitude: The state of being a slave or being completely subordinate to someone stronger.
Forced and compulsory labor: Any work or service in which a person is compelled under the threat of punishment and without the full will of that person.
Bonded labor: The payment of debts not in money but directly by labor and production power.
Child labor: The work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development.
Human trafficking: The illegal transport of individuals by force or deception for the workforce or activities that benefit others financially.
This policy demonstrates Eti Soda Inc.’s commitment and approach to fighting against modern slavery.
Application of the Policy
Breaches of the Policy
This policy will be reviewed annually by the Board of Directors of Eti Soda Inc. concurrent with the Modern Slavery Statement.
Purpose of the Policy
Eti Soda Inc., we prioritize the sustainable implementation and adoption of our ethical rules to protect our ethical behavior culture. This policy aims to guide our employees to report any legal, policy, or ethical code violations that they detect or suspect in good faith based on confidentiality, without being subject to any retaliation or grievance.
This policy applies to all Eti Soda employees. Besides, it can be used by anyone in our supply chain to report concerns about our operations or behavior.
Scope of the Policy
Issues that can be reported under this policy:
Examples of reportable topics include, but are not limited to:
Reporting Concerns and Complaints
Detailed information is expected to be given as much as possible so that the notification can be investigated quickly and efficiently. Some topics that may be useful are listed below:
Delivery of Concerns and Complaints
Address: On behalf of the Chairman of the Ethical Conduct Board
Eti Soda Inc.
Yeşilağaç Mh. Gürağaç Kümeevler No:47/A
Beypazarı Ankara / Turkey
Notification can be made anonymously. However, as this may prevent the report from being investigated in detail, the investigation may not be possible to complete. Making the notifications by specifying the name will enable the claim to be investigated more quickly and efficiently by contacting the source in case of need.
The identity of the reporting person will be kept confidential unless he has his permission or is required by law. Within the scope of this policy, we undertake that we will take all necessary steps to protect the employee who makes a notification from retaliation and all kinds of victimization
Actions that may cause grievance include, but are not limited to:
False or Misleading Allegations
The employee must have reasonable grounds to suspect that the information disclosed when making a report is accurate. In this context, if it is determined that the information given in good faith is wrong, no disciplinary action will be imposed on the notifying person.
Deliberate false and misleading claims will be considered a serious matter that may result in disciplinary action, as it would be a violation of our Code of Business Conduct.
Handling of the Complaint
The Ethics Committee is responsible for investigating and concluding the complaints and claims reported. The Ethics Committee will examine and record all incoming complaints and concern reports, investigate if an investigation is required, finalize it, report it to the Board of Directors, and ensure that necessary measures are taken. The action taken will depend on the nature and severity of the concern. The investigation process referred to in this policy will be conducted fairly:
The following information will be provided in writing within a reasonable time to the notifying person:
This Policy will be reviewed annually by the Board of Directors to ensure its adequacy and effective implementation.
Purpose of the Policy
Our main objective of Anti-Bribery and Anti-Corruption Policy is not to accept or not to give the products and services, which means as bribery or exceeds the intention within the scope of Our Responsibilities Against Society and Humanity, to respect laws and harmonize legislations, never bribing and not to give any facilitation payment to third parties on purpose, not to pursue any relationship with third parties, i.e. firms and business partners that we procured external service) who demand and/or offer any bribery/corruption.
Bribery: Cash or non-cash interests provided illegally to a person or third parties who have access/influence to the person in order to influence the decisions and practices related to the person’s duty, to do a job, not to do it, to accelerate, to slow down and to perform similar actions in a way that is contrary to the requirements of the duty,
Corruption: Abuse of a person’s realm of authority to gain unfair advantage for him/herself or for another person,
Presents: The product that does not require any financial payment and is generally given by people or customers with whom we have business relations as a thank you or commercial courtesy
Representation and Hospitality: Activities of Eti Soda Inc. within the scope of social events, accommodation, dinner invitation, training, conference, symposium and seminars and similar activities,
This policy shows Eti Soda Inc.’s Anti-bribery and Anti-Corruption Undertaking and anti-corruption and its approach to anti-bribery and anti-corruption.
Implementation of the Policy
Gifts and Entertainment: Gifts or hospitality will never be accepted from any supplier unless they are of truly symbolic value. It will be ensured that all the gifts and entertainment proposed are in accordance with the values of Eti Soda.
Representing the Company: In business relations, professional behaviors will be followed in accordance with the values of Eti Soda. Speaking and writing on behalf of Eti Soda will be avoided unless legally authorized.
Bribery and Facilitation Payments: This type of payment will never be deliberately made or demanded to third parties. Regardless of its purpose; receiving, giving, offering or money laundering is unacceptable.
Donation payments (Contribution to the Society): Only donation payments will be made in line with our public interest and / or corporate values and our working strategies.
Conflicts of Interest: No money will be accepted from third party persons or companies that have a business relationship with Eti Soda. Regardless of its purpose, it is unacceptable to provide benefits and interests.
Just Fair Competition: Our employees are responsible for complying with the competition laws in all markets and not violating the intellectual and property rights of third parties.
Fight Against Money Laundering: Our employees should avoid being associated with the criminal activities of others (even if innocently) in order to protect the reputation of Eti Soda and not to take criminal responsibility.
Case of Breach
The company is expected to act transparently and to provide the information requested by our company,
Corrective action is expected to be implemented as soon as possible to end the relevant situation, and it is expected to monitor the effectiveness of the measures taken,
Depending on the content of the contract signed with the firm, the relationship may be terminated, suspended or the volume of business reduced.
This policy will be reviewed once a year by the Board of Directors simultaneously with the Anti-Bribery and Anti-Corruption Statement by Eti Soda Inc.
This policy has been established to clarify the expectations and obligations of suppliers, business partners and subcontractors (each a “Supplier” and collectively, the “Suppliers”) of Eti Soda Uretim Pazarlama Nak. ve Elektrik Ur. San. ve Tic. A.S. (“Eti Soda”). Eti Soda values its partnerships with Suppliers and fully recognizes that our mutual success is built on open communication and a commitment to common principles and business practices. Accordingly, Eti Soda has set high standards for the way it conducts business in the areas of regulatory compliance, social responsibility, and environmental stewardship. It is the responsibility of each Supplier to ensure that its employees, agents and representatives understand and comply with this Supplier Code of Conduct (“Code”). Eti Soda’s own code of conduct (available on request) outlines the standard of conduct from individuals working at Eti Soda.
Ethics and Legal Requirements
Suppliers will conduct their business in a legal and ethical manner and act with integrity. Further, they will ensure that all third parties and subcontractors are in full compliance with contractual agreements and compliance requirements. Including:
* Compliance with Applicable Laws and Regulations
Meet and document compliance of all applicable regulatory and statutory requirements.
* Avoid Conflicts of Interest Take steps to disclose, manage and document any actual, potential, or perceived conflicts of interests in relation to the Supplier’s engagement with Eti Soda; Avoid any conflict of interest when interacting with Eti Soda employees; and Notify Eti Soda of any inappropriate gifts or hospitality offered to Supplier employees which might influence or appear to influence any Supplier employee decision in relation to WE Soda.
* No Bribery
Refrain from engaging in any form of commercial bribery with its suppliers, agents or customers, nor offer any incentive to any Eti Soda employee or family member of a Eti Soda employee in order to obtain or retain business; and
Abstain from any form of governmental bribery or facilitation payment with any political, regulatory or other government employee and comply with all applicable laws dealing with the bribery of government officials, including, as applicable, the U.S. Foreign Corrupt Practices Act; the Organisation for Economic Co-Operation and Development’s Anti-Bribery Convention, the UK Bribery Act and Turkish anticorruption laws.
* Anti-Money Laundering
Refrain from engaging in any activity, practice or conduct which could be construed as a violation of all applicable law relating to the prevention of money laundering and terrorist financing including, without limitation, the Law No: 5549 on Prevention of Laundering Proceeds of Crime.
* Fair Competition
Comply with all applicable laws regarding fair competition and antitrust; and
When preparing proposals, bids or undertaking contract negotiations for Eti Soda and our clients, Suppliers must be certain that all statements, communications and representations are accurate and truthful.
* Protect Information
Safeguard Eti Soda’s confidential information and act to prevent its misuse, theft and improper disclosure; Process and store information as agreed with Eti Soda and in accordance with the Law No: 6698 on the Protection of Personal Data and other applicable legislation; Have appropriate privacy / data protection and information security policies and procedures in place to protect personal and confidential information; and Notify Eti Soda immediately of any actual or suspected privacy breaches, security breaches, or losses of our information and assist Eti Soda in managing any consequences arising from such events.
* Financial Integrity
Not engage in any activity that is designed, or can be reasonably construed, to perpetuate a fraud; and Comply fully with all their obligations in relation to all taxes due within the jurisdictions in which they operate. Suppliers must not participate in tax evasion or facilitate tax evasion by others. Specifically, we expect our Suppliers to have contracts, policies, systems, and /or procedures in place to ensure that all who act for them or on their behalf, also comply with such obligations.
* Identification of Concerns
Provide means for Supplier employees and agents to report concerns or potentially unlawful activities in the workplace. Treat any report in a confidential manner. Investigate such reports and take corrective action if appropriate.
Human Dignity and Labour
Suppliers must abide by applicable employment standards, labour, non-discrimination and human rights legislation. Where laws do not prohibit discrimination, or where they allow for differential treatment, Suppliers are expected to be committed to non-discrimination principles and not to operate in a way that unfairly differentiates between individuals.
All labour must be voluntary. Suppliers shall not support or engage in slavery or human trafficking in any part of its supply chain. Suppliers are expected to protect the human rights of their employees and to treat them with dignity and respect. Including:
* Modern Slavery and Human Trafficking
Comply with applicable laws and regulations of the countries in which they operate with respect to slavery, servitude, prostitution, forced and compulsory labour and human trafficking, including, without limitation, the Turkish Criminal Law No. 5237 and International Labor Organization; Incorporate modern slavery clauses in all agreements in its supply chain related to the provision of services and products to Eti Soda; Cooperate with Eti Soda as it carries out periodic due diligence on the Supplier to ensure that the necessary measures are taken to prevent issues relating to modern slavery and human trafficking in the Supplier and its supply chain.
* Child or Forced Labour
Comply with the applicable child labour laws of the countries in which they operate and have zero tolerance of child labour that is not in accord with local laws; Ensure the prevention, detection and reporting of compelled, forced, involuntary, bonded, indentured or prison labour of any type and the trafficking or involuntary servitude of any worker; and Demonstrate zero tolerance of compelled, forced, involuntary, bonded, indentured or prison labour of any type and the trafficking or involuntary servitude of any worker.
Non-discrimination in hiring practices on grounds of race, creed, gender, religion, national origin, age, disability or sexual orientation or other factors as mandated by the Turkish Constitution (as amended) and the Turkish Criminal Law; and Prohibition of retaliation for speaking up and employees are free to raise concerns and speak up without fear of reprisal.
* Fair Treatment
Respect for workers, and a zero tolerance for any engagement in corporal punishment, violence or threats of violence, or other forms of physical coercion or harassment (including, without limitation, sexual harassment).
* Working Hours, Wages and Benefits
Working hours for Suppliers’ employees will not exceed the maximum set by applicable law and workers; Workers are entitled to appropriate breaks for rest as required by the Turkish Constitution; Compensation paid to employees will comply with applicable wage laws. Employees must be paid in a timely manner in accordance with such laws; and Commit to providing minors, women and persons with physical or mental disabilities with special protection concerning working conditions.
* Freedom to Work and to Terminate
Employment Ensure that every employee has the freedom to work and to negotiate and conclude contracts in the field of their choice;
Not deprive any person of their liberties; and
Without limiting Supplier’s obligations hereunder, Supplier shall allow workers to terminate their employment or work arrangement: without restriction; and without the threat or imposition of any discipline, penalty, retaliation, or fine or other monetary obligation.
* Freedom of Association
In accordance with applicable laws, respect the rights of employees to, whether formally or informally, associate freely, join trade unions, seek representation, and engage in collective bargaining and not interfere with or discriminate against workers choosing to belong to them.
* Compliance and Documentation
Implement and maintain a reliable system to verify the eligibility of all workers, including: age; eligibility; regulated/unregulated status and legal status of foreign workers; and Implement and maintain a reliable recordkeeping system regarding the eligibility of all workers.
Environment, Health and Safety
Eti Soda’s commitment to sustainability includes efficient use of resources, respect for the environment, and safe and healthy workplaces. Eti Soda expects its Suppliers to make similar commitments to continuously improve their environmental, health and safety performance. Including:
* Respect the Environment
Collaborate to eliminate waste and cost from the supply chain, such as programs to reduce emissions and waste, promote the efficient use of energy and natural resources, and encourage responsible management of their products and processes through their entire life cycle, and for their intended end use; and Document any actions that have been taken to minimise the environment impact of the Supplier’s products and services.
* Protect Health and Safety
Demonstrate and actively work to advance sustainable business practices and a clear commitment to a safe workplace by complying with Eti Soda’s site rules and guidelines, the Supplier safety check list, the Occupational Safety and Health Law and any additional Health and Safety legislation applicable to the Supplier’s industry;
Health, safety and security must be priorities in product manufacturing and in the provision of services and in planning for new products, facilities, processes and services; and
Employees must work in a safe and healthy workplace, with the appropriate controls, training, work procedures, and personal protective equipment.
* Community Engagement
Respect the traditions, cultures and laws of the countries in which the Suppliers operate and seek to employ local people on projects wherever possible.
Eti Soda strives for continuous improvement in all facets of operations and expects the same from its Suppliers. Suppliers will maintain a documented quality system that utilizes process controls and emphasizes defect prevention in addition to defect detection. Including:
* Communication Promptly notify Eti Soda of changes to goods or services that may adversely impact its product usage, service usage and/or business relationship; and Notify in advance of any plans to discontinue goods or services and channel all communications on terms, conditions and pricing through designated Eti Soda supply chain or departmental representatives and obtain prior approval before soliciting or reaching out to others in Eti Soda.
* Business Resumption and Contingency
Planning Develop, maintain and test the Supplier’s business continuity and disaster recovery plans in accordance with any applicable regulatory, contractual and service level requirements.
* Outsourcing and Subcontracting
Not to subcontract services performed for Eti Soda or outsource activities that directly impact the delivery of goods and services to Eti Soda, without prior written approval; Provide Eti Soda with information relating to the locations of where the work will be performed, including the possibility of cross-border movement of any Eti Soda data, and the identity of parties involved in the provision of the services; Where Suppliers are outsourcing certain activities in connection with Eti Soda, monitor the outsourcing or subcontracting engagement to ensure compliance with the Suppliers’ contractual obligations and with this Code, and provide evidence of such monitoring to Eti Soda upon request.
Give a timely response to requests for information, technical assistance, or corrective actions; commit to openly share information on all elements of cost and cost improvement initiatives; and share sustainability and related data and, if necessary, cooperate in a sustainability audit.
Accept only specifications and requirements that can be met; provide prompt and professional customer service; and comply with purchase order and contractual obligations regarding schedules and deliveries for goods and services.
* Process Development
Partner to develop process improvements and new applications, in addition to providing goods, services or innovations that give Eti Soda a technical, process or service advantage over our competition.
* Productivity Improvements
Assist with research and the implementation of productivity improvements that result in lower costs every year as well as provide ideas and solutions that will improve the cost of goods and services.
* Effective Use of Electronic Commerce
Cooperate to improve efficiency of interaction through the utilization of e-sourcing, einvoicing and other web-based electronic tools upon Eti Soda’s request; include purchase order numbers and reference numbers, where applicable, on all transaction documents; and participate in the automation of procure-to-pay processes, when applicable.
This Code is supplemental to any contract between Eti Soda and Suppliers. To the extent that more specific or stringent terms are agreed in a contract, the contract terms shall control. Suppliers must maintain management systems and controls to promote and facilitate compliance with applicable laws and the principles set forth in this Code. Suppliers should also apply these or similar principles to the subcontractors, suppliers and other third parties they work with in providing goods and services to Eti Soda If you have any questions about this Code, you should contact your local Eti Soda procurement representative.
Monitoring and Reporting of Violation
Eti Soda reserves the right to assess and monitor Suppliers’ compliance with the requirements set forth in this policy by conducting periodic audits (on site or otherwise) and third-party assessments following reasonable prior notice to Suppliers. Any person with reason to believe that the spirit or principles of this Code are not being respected by a Supplier is asked to report to: E-mail: firstname.lastname@example.org
ISSUE DATE: 07.01.2021