Mioro Bribery Risk Management Procedure

 

PR.231 Publication Date: 20.12.2017 R.OI Revision Date: 23.12.2024

 

Aim

To ensure that Mioro operates with integrity, ensure compliance with corruption laws, identify and reduce bribery risks, ensure transparency in business processes and encourage employees’ compliance with the company’s bribery policies.

 

Bribery Risk Management Procedure

 

  1. Risk Assessment

 * *Purpose**: To identify areas of Mioro’s operations with the most sensitive bribery risks. _ Steps**

  1. Conduct a comprehensive risk assessment to identify potential bribery risks across different departments and locations.
  2. Separate risks into low, medium, and high categories based on complexity, geographic location, and transaction value.
  3. Seek help from a risk management expert, especially if operating in complex operations or multiple locations.
  4. Document findings in a **Risk Assessment Report** for review by senior management.
  • * *Documentation**
  • Internal management reports.
  • Risk assessment forms and meeting minutes.
  • Supplier and purchasing risk analysis reports.
  •  

  1. Third Party Gift Registration

  • * *Purpose**: To track and ensure transparency of all gifts, donations, sponsorships, community payments and hospitality expenses.
  • * *Steps**
  1. Create a **Third Party Gift Registry** to document all gifts given or received by your employees or business partners. 2. Add the following information to the record:
  • Name of gift giver/recipient.
  • Description and value of the gift.
  • Date and purpose of the gift.
  • Approval from the relevant authority.
  1. Integrate gift registry into your existing payment systems, if possible.
  2. Review and update the record regularly.
  • * *Documentation**
  • An up-to-date and complete gift registry. – Periodic gift registry review reports.

 

  1. Whistleblowing Mechanism

 * *Purpose**: To provide a safe platform for employees and stakeholders to anonymously report bribery and corruption concerns.

  1. Establish a **Whistleblowing Mechanism* * that can be accessed through the following channels:
    • **E-post**: [compliance@mioro.com.tr]
    • * *Online Platform**: [www.mioro.com.tr/hotline] (http://www.mioro.com.tr/hotline)
  2. Provide training and internal communications to inform employees about the mechanism.
  3. Establish a Whistleblower Committee to investigate and respond to reports quickly and confidentially.
  4. Keep records of reported incidents, investigation results and remedial measures.
  • * *Documentation**
  • Whistleblowing policy and procedure documents. – Records of reported incidents and solutions.

 

  1. Education and Awareness

 * *Purpose**: To ensure that all employees understand Mioro’s bribery policies and how to recognize and manage bribery risks.

_ Steps** :

  1. Develop a bribery risk training program that covers the following topics:
  • Identifying and managing bribery risks.
  • Notification procedures.
  • Consequences of policy violations.
  1. Hold mandatory training sessions for all employees and record attendance.
  2. Distribute training materials and issue certificates to those who complete.
  • * *Documentation**
  • Training program calendar and attendance records. – Training materials and certificates.

 

  1. Investigating and Responding to Bribery

 * *Purpose**: To handle suspected or actual bribery cases effectively and transparently.

  1. Appoint a Compliance Officer to lead investigations.
  2. Gather evidence, question relevant parties, and document findings.
  3. Implement corrective actions, including disciplinary measures, reporting to authorities, or policy updates.
  • * *Documentation**
  • Investigation reports and meeting minutes.
  • Records of actions taken and communications with stakeholders.

 

  1. Sanctions and Accountability

 * *Purpose**: To impose sanctions in case of non-compliance with Mioro’s bribery policy.

_ Steps**

  1. Develop a sanctions framework that includes disciplinary measures for:
  • Offering, accepting or facilitating a bribe.
  • Failure to report known cases of bribery.
  1. Apply sanctions consistently and fairly, complying with labor laws and company policies.
  2. Communicate the sanctions policy to all employees through training and internal communications.

* *Documentation**

  • Records of sanctions imposed.
  • Records of communications with managers, human resources or legal teams.

 

Monitoring and Reporting

  • Ensure regular review of bribery risk management processes, for example:
  • Audit of risk assessments and gift registry records.
  • Effectiveness of the reporting mechanism.
  • Participation and feedback of training programs.
  • Summarize bribery risk management activities and improvements by preparing annual compliance reports.

 

Contact Information

To Report Bribery Concerns:

* *E-mail**• compliance@mioro.com.tr

* *Online Platform**: www.mioro.com.tr/hotline

 

Policy Review

This procedure will be reviewed annually to ensure compliance with legal requirements and global anti-corruption standards.

Last Revision

Date: 23.12.2024

APPROVED BY THE BOARD

OF DIRECTORS

Mioro Gift Shop San. And Trade. I nc.