ETİK-EN111 ETİK-EN111

In addition to being organizations that strive to increase their profits under fair competition conditions, companies are also organizations that are expected to contribute to the economic development of their society. Therefore, managers and employees working in AkzoNobel Kemipol must comply with local and international laws and regulations, adopt the following business ethics rules of AkzoNobel Kemipol and act with correct judgment.

  1. AkzoNobel Kemipol strives to develop moral values that will provide an environment that respects human life and fundamental human rights and observes moral values at every stage of its professional activities.
  2. AkzoNobel Kemipol abides by the laws and social responsibilities in all its activities and acts fairly and impartially. It maintains healthy and correct relations with the state and other authorities, does not engage in any relationship that may pose a risk to social order or strong corporate activities.
  3. AkzoNobel Kemipol acts as a good corporate citizen, takes initiative in cultural, sports and social activities, supports activities such as accident recovery and disaster prevention to achieve a successful union with the society.
  4. AkzoNobel Kemipol accurately discloses all information about its activities, except where confidentiality is necessary and reasonable, and where it is beneficial to the public. The company takes care that the code of conduct does not go beyond the limits of its behavior that is considered acceptable in accordance with social norms.
  5. While AkzoNobel Kemipol develops / offers products / services, it also considers the issues of benefit to society and security.
  6. AkzoNobel Kemipol is aware that it must also be sensitive to environmental issues to survive as an institution.
  7. AkzoNobel Kemipol strives to provide its employees with a safe working environment and a good quality of life while at the same time respecting the character and freedoms of its employees.
  8. AkzoNobel Kemipol respects the culture and traditions of the regions in which it operates and acts in accordance with local social norms.
  9. AkzoNobel Kemipol carries out all transactions with the companies it deals with within the scope of purchasing and sales activities in good faith. There is no compromise on the provision of fair and correct trade environments and proper commercial activity.
  10. AkzoNobel Kemipol is aware of the importance of all intellectual property rights, including trade secrets, while respecting the rights of other individuals and organizations, it also protects its own rights.
  11. AkzoNobel Kemipol executes and maintains its records and reports regarding the performance of its activities in accordance with the relevant laws and regulations. AkzoNobel Kemipol also manages registered personal information in a way that prevents possible unintentional leakage and disclosure.

Business Ethics Principles

Employees

  
  • We take care to be in good faith and fairness in all our relationships.
  • Unless authorized by the company, we do not make a statement that would put the company under commitment.
  • We do not act in any way that may offend or harm other employees.
  • We do not harm the company by using our powers in favor of ourselves or our relatives, except for the duties expected from us.
  • Even if it is not included in the laws and regulations, we comply with the rules and social norms determined within the company.
  • It is inappropriate, and we do not accept any benefits (bribes, kickbacks, borrowed money, etc.) and gifts from sub-employers, vendors, suppliers, customers, competitors or consultants that may affect our objectivity and decision-making process.
  • When we receive such invitations / offers from relevant institutions and persons, we report the situation to our manager.
  

  Shareholders

  
  • We protect the rights and interests of the shareholders as determined by law.
  • We accurately explain the issues that need to be disclosed to the shareholders and the public in a timely manner.
  

 AkzoNobel Group and Affiliates

  
  • It can be considered that the AkzoNobel group to which we are affiliated does not provide a similar level of support to all its subsidiaries on the basis of trade conditions. In this case, we make sure that there is no different application from market principles.
  • We do not give or receive gifts with other companies within the group or as employees of partner companies. We do not entertain employees in other companies. Likewise, the opposite is also true. However, participation in business meetings approved by the administrative team and the exchange of small gifts or business lunches are acceptable.
  

State

  
  • We comply with the laws and regulations of all countries where we operate.
  • Some countries apply trade controls that restrict certain trade transactions and the cross-border movement of goods. We comply with all trade controls that apply to our business and provide accurate and truthful information to customs and other relevant authorities.
  • We ensure that the records of all our transactions are kept through an internal approval process so that they are subject to inspection when necessary.
  • We comply with anti-money laundering laws. We are alert to threats of fraud and report any suspicious transaction or activity.
  • We seek legal advice whenever we are unsure about day-to-day business activities and commercial laws.
  

  Society

  
  • Our main approach towards anti-social forces, which use the method of frightening and harassing the weak by responding violently to disagreements, is always not to gain material benefits or to be intimidated by such demands.
  • We reject any unsubstantiated money requests that arise in the event of such unfairness. At the same time, we contact the authorized institutions and obtain information on how to solve the problem.
  • We show sensitivity to the issues concerning society and we support the society for its positive development.
  

  Customer

  
  • Our goal is not only to provide quality products and services to the customer, but also to provide complete and accurate information.
  • Gifts, travel, and promotional materials to be given to customers, dealers and other third parties with business relationships are approved by the company's senior management. We do not allow applications other than this.
  • With the knowledge and approval of the top management, gifts / promotions given in accordance with commercial traditions can be accepted as gifts on behalf of the company.
  • Requests by customers for transactions with third parties can only be implemented with the approval of the general manager.
  

A)  Fair Competition

  
  • We support free and fair competition.
  • We know about Competition Laws and work within the framework of these laws in a tough but fair competition.
  • We do not participate in activities aimed at preventing or restricting competition against competitors.
  

B)  Avoiding Conflicts of Interest

  

While conducting our business, we cannot provide unfair advantage to ourselves, our relatives, our friends, or the persons or organizations we have relations with.

  • We do not borrow or lend money, goods, or services in personal relations with company customers, suppliers, subcontractors or other persons and organizations with which they have commercial relations.

  • It is not accepted by our company that people working in critical positions in our customers, suppliers and competitors are our first-degree relatives. In such a case, we inform the company management.

  • It is not accepted by our company that our customers or suppliers are our first-degree relatives who are authorized to make decisions. In such a case, we inform the company management.

  • We do not work in return for an advantage for another person or institution during working hours. However, outside of working hours, we can work for another person or institution, if we guarantee that they will not prevent us from carrying out our duties in the company and that we receive written approval from the General Manager. We can work in non-profit organizations and universities, with the written approval of the General Manager, in charity tasks.

  • We can make speeches and write professional articles on topics that do not violate company policies, provided that the approval of the General Manager is obtained for the use of the company name.

  • We can take part in political processes personally, if we do not engage in any activity during working hours and do not use our position in the company and company resources. As a company, we do not financially or otherwise support or make donations to political parties or political campaigning.

  • With the approval of the General Manager, we can make a statement or interview with a broadcasting organization without obtaining any personal gain.

  • In the event of a possible conflict or possible conflict with the customers, suppliers, subcontractors and other persons and organizations we are in contact with, we discuss this with our manager.

  

C)  Correct use of Company Resources

  

Timely, correct and effective use and safe storage of all resources and assets of the company (company land, buildings, production equipment, products, raw materials, packaging, office supplies) is essential.

  • We use company assets appropriately and responsibly and protect against any loss, damage or abuse.
  • We do not spare time for our private affairs during working hours and do not use people and vehicles for our personal works.
  • We do not accept private visitors during working hours unless it is mandatory and approved by the department manager.
  

D) Prevention of Insider Trading

  
  • We know that it is a legal offense and we do not attempt to obtain any commercial interest by using any confidential information belonging to the company, giving it to third parties, or trading shares directly or indirectly from stock exchanges.
  • We act with the awareness that AkzoNobel Kemipol’s trade secrets, information that will reduce competitiveness, employee rights and information, and agreements with business partners are within the scope of "confidentiality", we ensure their protection and confidentiality.
  • We do not share information and documents we have with unauthorized persons and authorities inside and outside of the institution for any purpose whatsoever.
  

Employee Safety

Whether we are inside the company, on a customer visit or traveling, we always follow safety rules and procedures.

  • All employees are responsible for health and safety. We provide equipment, procedures, and training to prevent injuries, and focus on carrying out our business safely.
  • We report injuries and safety related accidents.
  • We take the necessary measures to protect our employees, information assets and information systems, factories and administrative facilities against possible terrorism, natural disasters, and malicious attempts.
  • Terror, natural disaster, etc. We make the necessary crisis planning related to emergency crisis management to be created in cases of crisis, thus ensuring business continuity with minimum loss in the moment of crisis.
  • We meet all legal and other obligations regarding occupational health and safety and accept that these obligations are the common responsibility of all employees.
  • We act in accordance with the rules and instructions set for protecting the health and safety of workers and take the necessary measures.
  • We do not keep in the workplace any property or substance that is dangerous or illegal to the workplace or employees.
  • We do not possess or use drugs, addictive, mental or physical abilities restricting or eliminating substances in the workplace, and do not work in the workplace while under the influence of such substances.
    The rules created in accordance with these goals are specified in the Health, Safety and Environmental Risks Procedure (PR-SGC-001).

Product Safety

It includes product safety, regulatory compliance, protection of people from exposure to hazards, and management of hazardous materials. Therefore, product responsibility concerns all parties that design, develop, produce, market, transport and use the product.

  • We focus on managing the product responsibly in health, safety, and environmental aspects throughout its entire life cycle.
  • We label the products appropriately and communicate the product transportation requirements as specified in the legal obligations.
  • We prepare Safety Data Sheets of the products in accordance with the current legislation.

 Environmental Safety
  • While doing our job, we fulfill all legal requirements related to the environment and other environmental protection obligations.
  • We focus on reducing our environmental footprint by avoiding air, water, and soil pollution, consuming less energy, and generating less waste in our operations.
  • We develop environmentally friendly technologies and work to do more with less while being environmentally responsible.
The rules created in accordance with these goals are specified in the Health, Safety and Environmental Risks Procedure (PR-SGC-001).

Process Security
  • Many products, raw materials or materials that are not noticed at first glance can be used for different purposes. We impose restrictions to prevent such materials or technologies from being used in the production of weapons of mass destruction, such as narcotic, nuclear, and biological weapons.
  • We ensure that employees who carry out export and domestic sales know the legal obligations well and fulfill them in accordance with the company legislation.
  • We encourage and provide methods for employees to share the problems they encounter with their superiors and to take the necessary measures on time.

Information Security

Information security is the entire process of ensuring the continuity of work in institutions and organizations, identifying threats to information assets, and responding to openings within a reasonable time. Effective use of information, correct sharing and ensuring the confidentiality, integrity, and accessibility of information in this process are the common responsibility of our company and all of our employees.

To ensure Information Security for our business continuity and information assets in our company:

  • We operate an Information Security Management System compliant with ISO / IEC 27001 standard.
  • We comply with all legal regulations and contractual obligations regarding Information Security.
  • We manage risks against our information assets.
  • We organize activities to improve technical and social competencies to increase awareness of Information Security.

The rules created in accordance with these objectives are specified in the Information Security Procedure (PR-BS-010).
Internal and external audit mechanisms that prevent and reveal irregularities regarding the Code of Ethics are described in the relevant procedures of the Quality Assurance Unit.
 


 

Human Rights and Employment Relations
  • As company management and employees, we comply with all applicable laws and regulations regarding employment and working life.
  • We focus on being fair in our human resources policies and practices.
  • It is unacceptable to discriminate among employees within the organization based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability, and similar reasons.
  • We ensure that the workplace physical working environment and conditions are healthy and safe for all employees. We create a supportive, positive, and harmonious working environment for all employees and aim to prevent conflict environments.
  • We respect the private life and personal spaces of our employees.
  • We observe the physical, sexual, and emotional immunities of our employees as well as all their immunities. We value our employees and respect employee rights.
  • We evaluate the opinions and suggestions of our employees, take responses, and take measures to increase motivation.
  • We do not employ and do not accept child labor.

Ethical Rules Application Principles
 

1.  Employees' Responsibilities
  • To act in accordance with the laws and rules in all our works and under all conditions.
  • Reading, understanding, adopting, and applying AkzoNobel Kemipol Code of Business Ethics.
  • To consult with his manager and human resources if he becomes aware of or suspects violations related to himself or others.
  • To report as soon as possible any possible violations of himself or others (including terrorism, smuggling, human trafficking, organized and narcotic crimes, harassment, and other security violations, detecting that the customs and foreign trade transactions are not being processed in accordance with the existing procedures); to forward the notifications about these issues to the manager and / or the Ethics Committee in writing (via e-mail or notification form), either named or anonymously.
  • Cooperating with the Ethics Committee in ethical investigations and keeping the information about the investigation confidential.
  • Acting within the framework of confidentiality, justice and ethics in ethical reporting and investigation processes.
It should be observed that the notification mechanism is in favor of the company. It is very important that the notifier does not carry malicious purposes such as gossiping about the reported person or trying to adversely affect his career or personality. When deliberate reports that are false or libelous are detected, they are interpreted as a breach of ethics.

A. The Path to Follow While Making an Ethical Decision
 

Determining the Incident, Decision, or Problem
  • Have you been asked to do something you think is wrong, illegal, or unethical?
  • Are you aware of a potentially illegal or non-business ethical situation within AkzoNobel Kemipol or with your customers?
  • Do you have doubts that make it difficult for you to make decisions in terms of business ethics?

Think Before You Decide
  • Try to define the problem clearly.
  • Ask yourself why you have doubts and think about the options and consequences.
  • Think about who might be affected and to what extent.

Decide on an Action Plan
  • Determine your responsibilities. Review all relevant facts and information, refer to the established AkzoNobel Kemipol policies on the subject.
  • Evaluate the threats and think about how you can reduce them.
  • Try to create the best action plan. Consult others.

Test Your Decision
  • Review questions that should be asked ethically. Evaluate your decisions within the framework of the three main AkzoNobel Kemipol Code of Business Ethics, Integrity, Safety and Fairness.
  • Be sure to follow AkzoNobel Kemipol’s policies and laws.

Continue with Determination
  • Share your decision with the people concerned with your reasons.
  • Share what you learned and your success story.

B.  Questions We Should Ask Ourselves
  •  Is the situation against AkzoNobel Kemipol or practice standards?
  • Does it feel right and ethical to you?
  • Does it comply with the law?
  • Who else might be affected? (Other employees within AkzoNobel Kemipol, customers, you, etc.)
  • Would you be ashamed if other people knew that you were engaged in this behavior?
  • Is there any other ethical behavior that would not create conflict?
  • How would it reflect on the press and media?
  • What would a reasonable person think in the same circumstances?
  • Can you sleep comfortably at night?

C.  Ethical Rules Violation Notification Method

If violations of ethical rules are detected, the person who detects it is obliged to report a violation, named or anonymous, in line with the above-mentioned evaluations. The methods of reporting violations are as follows.
  •  Ethical Rules and Information Security Violation Notification Form (FR-BS-036) is filled. This form can be accessed through the institution's document management system, QDMS. The completed form is put in the Code of Ethics and Information Security Violation Notification boxes located in the central cafeteria and production area.
  • An e-mail describing the report is sent to etikurul@ akzonobelkemipol.com.tr.

The personal information of the employee who reports the violation is under the protection of the corporate management, his name and identity cannot be disclosed.

Violation notifications are discussed by the Ethics Committee within two business days from the date of notification. In case the decision taken confirms the violation, it can be referred to the Information Security Committee or the Disciplinary Committee or decided by the Ethics Committee, depending on the content of the issue. After the end of the process, the notifier is informed about the results of the notification and the decisions.

2.  Managers' Responsibilities
  • Ensuring the establishment and maintenance of a behavioral culture and working environment that supports ethical rules.
  • To set an example for the team in all matters within the scope of ethical rules, to inform the employees about the ethical rules.
  • To support its employees in submitting their questions, complaints, and notifications about ethical rules.
  • Guiding on what should be done when consulted, considering all notifications communicated to him, and conveying it to the Ethics Committee as soon as it deems necessary.
  • To ensure that business processes are made in a way that minimizes risks related to ethical issues and that they comply with ethical rules.

3. Responsibilities of the Ethics Committee Members

Our company's Ethics Committee of the following members:

              General Manager (Chairman of the Ethics Committee)
               Assistant General Manager - Warehouses
               Human Resources Director
               Company Lawyer
               Electrical Maintenance Foreman
  • To be the person consulted on ethics within the company, to show direction.
  • To convey to the Ethics Committee any nonconformities that cannot be resolved within the company or require investigation.
  • To report ethical questions and nonconformities to the Ethics Committee regularly or when necessary.
  • To provide the necessary support to investigations in the investigations conducted by the Ethics Committee.
  • To observe and monitor the effectiveness of the ethical code practices carried out in the company and to contribute to the practices.

4.  Ethical Leader’s Responsibilities 

As part of the Business Ethics practices in our company, the Deputy Polymer Production Manager has been appointed as the "Ethical Leader".

  • Providing ethical leadership and guidance to all employees.
  • To encourage and support the creation of corporate leadership and corporate culture.
  • Guiding senior management on ethical issues.
  • To protect the ethical values and reputation of the institution, together with the senior management and the ethics committee.

5.  Disciplinary Practice
As a result of violations of the Code of Ethical Conduct, penalties determined within the framework of AkzoNobel Kemipol Disciplinary Regulations are applied. These penalties are described in the Disciplinary Regulation according to the action subject to violation.

For your questions and notifications, you can use the e-mail and postal addresses below or contact the members of the Ethics Committee directly.
E-mail etikkurul@akzonobelkemipol.com.tr
Adress AkzoNobel Kemipol San. ve Tic. A.Ş. 
Kemalpaşa OSB Mahallesi İzmir-Ankara Yolu (Ansızca) Küme Evleri No:287 AkzoNobel Kemipol Kemalpaşa–İZMİR
Phone 0 (232) 870 14 70
0 (232) 877 00 70