Business Ethics Policy

At MİORO, integrity and honesty are our priority values in all business processes and customer relationships.

Our policy covers confidential and proprietary information belonging to our company, information that could create a disadvantage in terms of competition, trade secrets, financial information, information regarding personnel rights, information about our customers, employees, and other relevant individuals and organizations we work with, as well as information within the framework of “Confidentiality Agreements” concluded with third parties. Employees of the company refrain from using the name and power of the company for personal gain by avoiding conflicts of interest.

1.0 APPLICATION RULES

1.1 MİORO Employee Relations

MİORO values its employees and treats their rights with respect. The policy of “Our most important capital is our human resources” is one of the fundamental principles adopted by MİORO since its establishment. In this context;
·      Seeking suitability for the job as the sole measure in recruitment and employment, ensuring equal opportunities without any discrimination based on gender, etc.,

·      Attracting the most qualified young people and experienced professionals to our company who will take our company forward,

·      Maximizing the benefits of employees’ talents, strengths, and creativity,

·      Providing equal opportunities and opportunities for training, guidance, and development of employees,

·      Rewarding success with fair and competitive wage policies, effective and objective performance evaluation systems and practices,

·      Increasing employees’ loyalty to the company by providing equal opportunities in appointments, promotions, rotations, and rewards,

·      Providing employees with clean, healthy, and safe working conditions,

·      Creating and maintaining a transparent and mutually respectful working environment where cooperation and solidarity are the most important elements,

·      Not tolerating harassment, coercion, and mobbing in the workplace,

·      Not employing child labor in the workplace,

·      Evaluating and responding to employees’ views and suggestions and taking motivating measures,

·      Not sharing employees’ special information with third parties without the employee’s permission and knowledge, except for legal obligations,

·      Respecting human rights, establishing basic principles

1.2 MIORO External Relations

The basic principles guiding MİORO’s relations with its stakeholders are listed below:

1.2.1 Communication with Stakeholders

To represent the MİORO brand in a way that does not harm its reputation before the society and to increase its reputation,
Keeping communication channels open with stakeholders, benefiting from their criticisms and suggestions, and ensuring the continuation of positive relations.

1.2.2. Compliance with Laws and Legal Procedures

·      To adopt as a principle to act in compliance with all relevant laws, rules and regulations in the countries of operation and new countries to be entered, as well as the International Conventions to which the Republic of Turkey is a party,

·      To manage, record and report all business activities and the accounting system in a complete and appropriate manner in accordance with the law.

·      Ensuring that contracts with third parties and organizations are clear and understandable in accordance with applicable laws, regulations and ethical rules.

1.2.3. Customer Relations

·      Creating value for customers and meeting their demands and requirements at the highest level,

·      Providing quality products and services and pursuing stable policies,

·      To be professional and fair in relations with customers within the framework of courtesy rules,

·      Protect customers’ personal information and confidentiality in accordance with applicable laws,

·      Not providing misleading and incomplete information to customers.

1.2.4. Supplier Relations

·      To select suppliers to work with meticulously and diligently, to ensure that they do not engage in unethical or illegal acts, to make the necessary examinations and determinations in line with the relevant application principles, to encourage them to fulfill their legal obligations, to respect human rights, to act in accordance with business ethics and anti-corruption principles,

·      To make decisions with objective criteria in the selection of suppliers,

·      Comply with reasonable confidentiality and occupational safety rules requested during supplier audits and visits.

1.2.5. Competitor and Rivalry Relations

·      Not to enter into agreements and concerted practices with competitors or other persons or entities that directly or indirectly aim to prevent, distort or restrict competition, or that have or may have the effect of preventing, distorting or restricting competition, in any way whatsoever, except within the limits permitted by the legislation. To comply with the provisions of the Law on the Protection of Competition and related legislation.

·      In cases where it has a dominant position in a particular market, either alone or together with other undertakings, not to abuse this dominant position,

·      Not to meet and exchange information with competitors in order to determine market and/or competition conditions together. Avoiding all kinds of meetings and transactions that may lead to or be characterized as such in meetings such as associations, assemblies, chambers, professional unions, etc., and other private or professional meetings and negotiations attended on behalf of the Company. In addition, if confidential information of competitors reaches the employee, the employee must inform his/her senior manager.

1.3 Ethical Rules of Conduct for Employees

It is the primary responsibility of all MİORO employees to ensure that the name of MİORO continues to be associated with professionalism, honesty and trust. Within this framework, the expectations from MİORO employees are listed below:
·      To always comply with the law,

·      To fulfill their duties within the framework of basic moral and human values,

·      To act with fairness, good faith and understanding in all relationships for mutual benefit,

·      Not to obtain any unfair gain from individuals and organizations for any purpose whatsoever, not to take or give bribes, to prevent such acts to the extent of their knowledge, to act in accordance with the rules of anti-corruption, not to forge documents,

·      To act in accordance with the relevant rules of business ethics and all application principles that support these rules in the duties carried out, and in this context, not to behave in a manner that prevents other employees from performing their jobs properly, and not to disrupt the work harmony,

·      The principle is not to make facilitation payments,

·      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 information and information systems, as if they were personal property, and to protect them against possible loss, damage, misuse, misuse, abuse, theft and sabotage,

·      Not to use working time and company resources directly or indirectly for personal benefit and/or political activities and interests, with or without monetary value.

1.3.1. Asset and Knowledge Management

All company regulations, commitments, and regulations regarding asset and knowledge security and confidentiality are considered complementary to the following items

1.3.1.1. Intellectual Property Rights

·      To ensure the legal initiation and completion of transactions to secure the intellectual property rights of newly developed products, processes, and software, and to prevent the sharing of such inventions and information with third parties without written approval,

·      To avoid the unauthorized use – knowingly – of patents, copyrights, trade secrets, trademarks, computer programs, or other intellectual and industrial property rights belonging to other companies,

·      To take necessary precautions to protect our rights when it is necessary to share any confidential information related to MİORO’s intellectual and industrial property rights with third parties, in accordance with relevant procedures

1.3.1.2. Knowledge Management

·      To ensure that all records are kept and archived in a healthy manner within the legal timeframe,

·      Not to respond to information requests falling into the confidential category for the company from third parties without senior management approval,

·      To exercise the necessary diligence to ensure that the statements disclosed by the company and the reports provided are accurate.

1.3.1.3. Security and Crisis Management

·      Take necessary measures to protect company employees, information and information systems, factory, and administrative facilities against potential terrorism, natural disasters, and malicious attempts, and ensure communication,

·      Make necessary crisis planning for emergency crisis management in case of terrorism, natural disasters, etc., to ensure business continuity with minimal loss during a crisis,

·      Take all necessary precautions to prevent theft or damage to company assets.

1.3.1.4. Privacy

·      Act with the awareness that financial and commercial secrets of MİORO, information that may weaken MİORO’s competitiveness, employee rights and information, and agreements with business partners are within the framework of “confidentiality,” ensuring their protection and confidentiality,

·      Do not share information learned in the course of work and the documents they possess with unauthorized individuals and entities within or outside the organization for any purpose, and do not use them for speculative purposes (directly or indirectly),

·      Do not use non-public information about MİORO, its customers, and other individuals and companies it does business with for any purpose other than the intended purpose, and do not share it with third parties without obtaining necessary permissions.

1.3.1.5. Social Media Usage

Act in accordance with MİORO culture in communications and sharing on public forums, web platforms, and all kinds of platforms on social media channels not provided or controlled by MİORO.

1.3.2. Avoiding Conflict of Interest

Conflict of interest refers to the situation where employees have or may have any kind of benefit or personal interest related to themselves, their relatives, friends, or the persons or organizations with whom they have a relationship, which may affect or may affect the impartial execution of their duties.

1.3.2.1. Not Acting in Favor of Self or Relatives

·      Not to provide unfair benefits for oneself, relatives, or third parties using title and authority,

·      To take care not to fall into a conflict of interest situation with personal investments made, with the current employer,

·      To ensure that personal investments or activities outside of any business activity do not hinder the employee’s ongoing duties at MİORO in terms of time and attention, and to avoid situations that prevent focusing on primary tasks.

·      To inform the superior if there is a first-degree kinship between the employee and the person who is in a first-degree decision-making position in the company as an employee or as a customer or supplier in the same position.

·      To inform the superior if it is learned that their relatives have shares or financial interests in another company with which there is a commercial relationship.

1.3.2.2. Former Employees Doing Business with MİORO

·      After leaving the company, personally or as a partner in another company, engaging in activities such as selling, contracting, consulting, brokering, representing, franchising, or similar to MİORO may create a negative perception, which is a very important point to be careful about. It is also important to note if a former employee holds a top management or decision-making position in another company.

·      It is necessary to act in accordance with the interests of the Company before, during, and after such a process, to adhere to moral and ethical rules, and not to allow conflicts of interest before and after the process.

·      In the case of such a supplier, the relevant manager must prepare a report stating that there is no inappropriate situation and inform their superior.

·      If there is an inappropriate situation, commercial relations should not be established with the relevant individual or company.

·      Except for exceptional cases requiring managerial approval, to prevent negative perceptions, approval should not be given to such commercial relationships until 2 years after the employee’s departure from the Company.

·      If a former employee is re-employed, it is required that their relationship has not been terminated due to non-compliance with the principles stated in the Code of Ethics and Application Principles

1.3.2.3. Sharing and Trading Insider Information

Knowing that attempting to obtain any commercial benefit by using or disclosing any kind of confidential information belonging to MİORO, such as commercial, financial, technical, legal, etc., or providing it to third parties, is a legal offense, and strictly refraining from it.
Taking necessary measures to preserve confidentiality and comply with confidentiality obligations even after leaving the company.

1.3.3. Combating Corruption

MİORO is opposed to bribery and all forms of corruption. Corruption harms commercial life, institutions, and employees, irreparably damaging commercial reputation and integrity. MİORO is extremely diligent and sensitive in combating bribery and corruption. All employees and third parties acting on behalf of MİORO are obligated to adhere to anti-corruption rules.

1.3.3.1. Receiving and Giving Gifts

MİORO prohibits all its employees, as a principle, from engaging in relationships with customers, suppliers, and all third parties that could create the impression of providing material benefits, including offers and acceptance of gifts, invitations, and entertainment. The following criteria must be adhered to in conducting relationships with individuals and organizations, whether private or official, who wish to establish or maintain business relationships with MİORO:
Except for items given in accordance with legal and commercial customs, traditions, and practices, no gift should be accepted or offered that creates the impression of irregularity, could lead to a dependency relationship, or could be perceived as such (such as providing privileges or references).
Gifts should not be given in any form that can be converted into cash or cash equivalents (such as gift certificates).
No discounts or benefits that could be perceived as inappropriate should be requested from or offered to suppliers, customers, or third parties, and should not be accepted if offered

1.4 Occupational Health and Safety

Our community aims to fully ensure occupational health and safety in the workplace and at workstations. Employees adhere to the rules and instructions set for this purpose and take necessary precautions. They embrace the principle that improving occupational health and safety is the collective responsibility of all employees.

1.5 Civil Society Organizations and Political Activities

MİORO does not make donations to political parties, politicians, or political candidates. Demonstrations, propaganda, and similar activities for political purposes are not allowed within the workplace premises. Company resources (such as vehicles, computers, email) cannot be allocated for political activities. Membership in and participation in the activities of any civil society organization on behalf of the Company can be done with the knowledge of the Company.

1.6 Principles of Implementing Ethical Behavior Rules

1.6.1. Obligation to Report Violations

Employees are obligated to report to their immediate supervisor or, if the situation involves the immediate supervisor or if the immediate supervisor does not take any action regarding the incident suspected of violating the Code of Ethics or applicable laws and regulations of MİORO, to the Employer. Reporting can also be made to the designated email or phone line if available. Disclosure of the report made by an individual in a way that negatively affects peace in the workplace or business relationships with third parties will be strictly prevented. No employee who refuses to engage in unethical behavior and makes a good faith report shall be threatened, retaliated against, or harmed in any way, either in the workplace or outside. Such behavior is considered a violation of ethical rules and appropriate disciplinary actions are taken. It is crucial that the reporter is free from intentions such as spreading rumors about or trying to negatively impact the career of the reported individual. Therefore, confidentiality, objectivity, and adherence to ethical rules are extremely critical in the reporting and investigation process. Both the reporter and those managing the process must give maximum importance and attention to this issue. Deliberate false or defamatory reports are considered a violation of ethical rules. Management ensures the provision of an environment conducive to the operation and effectiveness of the reporting mechanism. Employees are educated to support management in ensuring the effectiveness of the reporting mechanism.

1.6.2. Disciplinary Action

1.6.2.1. After General Violations

of Ethical Behavior Rules, the following disciplinary actions are taken:
If intentional abuse is determined, termination of employment (in accordance with relevant articles of employment law) and initiation of legal proceedings if deemed necessary. The beneficial work done by the individual in the past cannot partially or completely serve as a reason for amnesty on the decision taken if there is proven intentional abuse.
If there is no abuse or negligence due to carelessness or lack of knowledge, a verbal or written warning appropriate to the impact of the incident is given.

1.6.2.2. Obligations of Third Parties

All employees, suppliers, and customers:
·      Must commit to complying with the Code of Ethics Policy.

·      Must understand, accept, and fulfill the duties specified in ethical rules and similar regulations; they should make ethical behavior a habit while performing their duties.

·      Must report without delay to their Manager when they or someone else violates ethical rules or are forced to violate them.