OUR CODE OF ETHICS

As GunSu Steel, we attach great importance to our ethical rules in terms of both the continuity of our company's activities and the motivation of our personnel and the peace in the work environment. A working environment in accordance with ethical values, shaped by the contributions and efforts of our management team and in line with our ethical rules, plays an important role for our company on the path to success. In this context, the authorized persons or our company's management team;

– To be an exemplary role model for the staff with their thoughts, attitudes and behaviors,

– To be consistent in decisions and open to feedback,

– To abide by all legal regulations that our company is subject to in terms of ethics,

– It adopts the principle of ensuring that the ethical rules are clearly understood by the staff and providing an environment where they feel comfortable to openly express any problems that may arise.

1- USE OF COMPANY RESOURCES

Efficiency is essential in the use of our company's financial resources. When using the communication networks provided by the company, the company regulations must be followed in order to use the information safely and effectively. Although it is not considered ethical to establish financial relationships with any customers, suppliers and experts and to seek personal gain, it is considered as the use of our company's financial resources. The main headings regarding the use of our company's financial resources are as follows:

1. Representation Expenses

– Company owners and managers can buy gifts and take their team and employees to fun events without discrimination in order to motivate them.

– Representation expenses are used only in areas where they are relevant for business negotiations and buyers.

2. Donations, gifts and treats on behalf of the company

– On special occasions, the company can give gifts on its behalf to buyers and personnel in line with its budget.

– Donations and aid on behalf of the company are made in accordance with the decisions of the company officials/shareholders.

3. Time Management

– Using time efficiently is one of the most important issues for our company. During business hours, our employees should not spend time on their personal affairs unless it is essential, urgent or an unusual matter.

– In our company, where the employees who work during working hours are rewarded for their efforts, it is very important for the staff to use their working hours efficiently.

– It is important for meetings to start and end on time in terms of efficient use of time. Therefore, it is important to come to meetings prepared.

II- RELATIONSHIPS

1. Relationships with Suppliers

In relations with suppliers, as in all other relations, an honest and impartial attitude must be adopted and ethical values ​​must be taken into consideration. Our personnel are obliged to comply with these ethical values.

2. Customer Relations

Customer satisfaction is among the most important values ​​for us.

Responding to and resolving customer complaints and requests in the fastest and most accurate way is among our priorities. Exploiting customer weaknesses under any circumstances and/or providing misleading information to customers is against our ethical values.

All complaints made by customers are immediately reported to the upper management.

It is against ethical values ​​and is not allowed for the personnel to have any personal business relationship with the company's customers, to borrow money from the customers or to lend money to the customers.

Within our company, customer satisfaction is the main focus, and we prioritize their needs and principles; We work with an understanding that responds to customer complaints and distribution in the shortest time and in the most accurate way. Even if it is company marketing, customer weaknesses cannot be exploited and profit-oriented activities cannot be pursued by providing incomplete or incorrect information.

• Customer complaints are immediately recorded in the management system and directed to the Customer Complaints Committee. Reporting of customer complaints to senior management is carried out meticulously by the relevant units within the principles of transparency.
• Employees cannot enter into personal business relationships with Company customers, borrow money, or lend money to customers.
• Purchasing goods or services from customers for a fraction of their value or for no consideration at all is considered as obtaining personal gain and requires disciplinary action up to and including termination of the employment contract.

3. Media Relations

Whether a fee will be charged for speaking at any media organization, giving interviews, seminars, conferences, or making a statement is decided upon approval by the General Manager. Obtaining personal gain from such activities is against our ethical values.

III- LIABILITIES TO THE COMPANY
1. Acceptance of Gifts, Invitations, Aids and Donations
i. Acceptance of Gifts;

Soliciting gifts from customers, consultants and suppliers is against our ethical rules and is not permitted.

It is not allowed to accept any kind of material benefit such as gifts, checks, discount cards, holidays that provide personal benefits that would put the company under liability. However;

If there is a possibility that the relationship with the customer will be negatively affected if the gift is not accepted,

Gifts that will not affect the financial decisions of the company may be accepted provided that senior management is notified.

It is stated that gifts that do not comply with the specified conditions cannot be accepted properly.

ii. Acceptance of Invitations;
Company meetings, conferences, dinner events and social activities organized by third parties;

– If it will not affect the decisions of the company employee who accepts the invitation in a way that will have consequences contrary to fairness, ethical values and equality,

– If it is in line with the company's policies, values ​​and interests,

– If there is approval from senior management,

acceptable.

 iii. Acceptance of Aid and Donations; Aid and donations cannot be approved from any person or institution that has an account relationship with our company. If a proposal is made, this issue must be shared with the upper management immediately.

2. Avoiding Conflict of Interest

Conflicts of interest may occur when company interests do not match personal interests or interests between customers. In such cases, it is necessary to act in accordance with the interests of the company. It is not allowed to use the company's goods or service information for personal interests. In the event of a conflict of interest, senior management must be informed.

It is unethical for our personnel to purchase goods or services from suppliers that the company has cooperated with for personal or commercial needs, even if the price is more affordable. Offers received from individuals who previously worked for us as personnel or business partners, in cases where they are currently working or collaborating directly or indirectly, should be evaluated by the management.

If there are family members working at customer or supplier companies, management approval must be obtained before collaborating. Similarly, if purchasing officers have relatives or friends at companies from which they receive offers, they must inform management of the issue before making a purchasing decision.

It is not appropriate for our personnel, other than those who communicate with suppliers and customers as required by their job description, to have close relationships with said suppliers and customers.

Our personnel working in our company;

– Cannot have personal interest relationships with customers or suppliers.

– In case of a conflict of interest between customers and staff; our staff must act equally, fairly and impartially.

– Under no circumstances should they act as guarantors for customers and suppliers, nor should they request that they act as guarantors. They should not enter into any legal or financial relationships with customers under any name that could damage commercial relationships, such as debt-receivable relationships.

– Invitations or tickets that are partially or completely covered by the customer may be accepted with the approval of the upper management. Similarly, they should not accept gifts that may create obligations for them.

– Must not give luxurious gifts to customers or potential customers and must not pursue a self-interested relationship with customers.

3. Working and Taking on a Job Outside the Company

– Our personnel must only work within our organization. They cannot be partners of any company except for purchasing shares on the stock exchange and cannot be referred to as merchants, tradesmen or freelancers. They cannot be members of the board of directors of other companies except for our company and group companies.

– Taking office in any foundation, association, federation, etc. institutions and organizations is subject to written approval of the senior management.

– Giving professional talks and conferences at universities or vocational schools may be accepted with the written approval of the senior management, provided that it does not disrupt their work.

4. Political Activities

Employees cannot take an active role in any political party while they are working for our company. Company managers cannot make such a request from them. They cannot provide material or moral support to political activities on their own behalf or on behalf of the company.

5. Non-Discrimination and Equality Among Employees

As our company; It has adopted the principle of treating all employees equally. Everyone should be treated equally regardless of ethnicity, religion, language, race, gender, age, marital status. Our personnel should also act in accordance with this principle adopted by our company. In case of a contrary situation; employees have the right to bring this situation to the upper management.

6. Personal Donations and Aids

Personnel can provide material and moral support to third parties other than other personnel in the company, and can take an active role in aid associations, provided that they provide information.

IV- GENERAL RULES

Our staff;
– Fulfill their responsibilities honestly and ethically,

– Protecting the company's brand and assets,

– Acting in accordance with all ethical values, confidentiality and policies of the company,

– They are responsible for protecting all personal data of people they come into contact with through their working lives.

Personnel are required to successfully complete all tasks requested from them as required by their positions. However, if they believe that the requested task is not in accordance with the ethical values ​​and policies of the company, they may share this issue with senior management without hesitation.

Protection of the Trademark

Protecting the GunSu Steel brand and strengthening it every day is among our primary missions as a company. Our personnel must also fulfill their responsibilities in line with this awareness.

Our staff should not use company e-mail addresses in their social media posts. At the same time, they should be careful not to violate confidentiality rules in any of their posts.

Professional Confidentiality

Our personnel must not share any information about the company with any person, institution or organization other than authorized company personnel and legal authorities. Persons who learn any confidential or undisclosed information due to their job description are obliged to keep this information confidential.

“Confidential information” includes all kinds of Company information that our personnel are or will be informed about in accordance with their job descriptions, whether verbally, in writing or via electronic media such as telephone or social media.

Our personnel may share the confidential information learned with other personnel who need to know it in accordance with company policies and with legally authorized authorities. It cannot be shared with any legal or private person other than these. Customer and supplier information, all kinds of reports, financial data, business plans, computer software, and services provided are considered confidential information.

Protection of Confidential Information

In protecting the confidential information of the company, our personnel are individually responsible for protecting the confidential information they know as per their job description. Care is taken not to leave any files on the desks and confidential documents are kept in a protected place. Passwords must be known only by the password owner. Copying of information is not allowed except for notification of business and legal obligations. No one other than company personnel can access the company's information and internet network. Everyone is obliged to perform transactions from their own computers, no one other than company personnel can use the company computer.

Compliance with Company and Legal Policies and Regulations

Personnel are obliged to comply with the company's policies and regulations. They will not abuse their duties and responsibilities and will not allow such abuse. They will stay away from events and situations that will allow such abuse. Personnel cannot be directly or indirectly involved in any crime. However, they are obliged to inform the upper management confidentially if they witness abuse of duty or direct or indirect involvement in a crime.

V- IMPLEMENTATION OF ETHICAL RULES

Personnel who violate the code of ethics may be subject to sanctions up to the termination of the employment contract for just cause by our employer company. For this reason, our personnel are required to perform their duties duly and in compliance with the relevant legal legislation, especially our Code of Ethics and the Labor Law. On the other hand, our personnel will be able to confidentially discuss with the senior management in case of any doubt as to whether any behavior is in compliance with the ethical rules.