• Representing our company to society and enhancing its reputation,
• Ensuring the company is managed with principles of trust and integrity, targeting sustainable growth and profitability, and managing resources, assets, and working time efficiently.

• Conducting all business activities and maintaining accounting systems fully and appropriately in compliance with the law, and reporting them when necessary,
• Adhering to all laws, rules, and regulations in countries where the company operates or plans new investments.

• Supporting initiatives that contribute to economic and social development,
• Demonstrating sensitivity to issues concerning society / country and supporting the positive development of society.

• Creating value for customers and meeting their demands and needs at the highest level,
• Providing quality products and services,
• Establishing long-term trust in relationships with customers,
• Enhancing customer satisfaction during and after the sales process,
• Avoiding misleading or incomplete information in communications with customers.

• Creating mutual value in relationships with suppliers and dealers,
• Maintaining open, direct, and accurate communication with suppliers and dealers,
• Using objective criteria for supplier and dealer selection,
• Adhering to confidentiality and occupational safety rules requested by suppliers/dealers during audits and visits.

• Except for the limits permitted by the legislation, not to enter into agreements and behaviours with competitors or other persons or entities, directly or indirectly, which have the purpose of preventing, distorting or restricting competition or which have or may have the effect of preventing, distorting or restricting competition in any way whatsoever,
• Not to abuse its dominant position in a particular market, either alone or together with other undertakings,
• Refraining from negotiations or exchanges of information with competitors aimed at determining market or competition conditions collectively,
• Avoiding any discussions or activities at meetings of associations, chambers, professional organisations, or other gatherings that could lead to situations mentioned above or be interpreted as such.

• Developing and ensuring effective implementation of environmental policies,
• Acting in accordance with the principles set out in the United Nations Global Compact and setting an example in this regard.

Intellectual Property Rights

• Ensure timely initiation of legal procedures to secure intellectual property rights for newly developed products, processes, and software,
•  Avoid unauthorised use of patents, copyrights, trade secrets, trademarks, software, or other intellectual property rights of other firms knowingly.

Information Management

• Maintaining accurate and complete records of all legal documentation,
• Not responding to requests from third parties for confidential company information without approval from senior management,
• Ensuring the accuracy of declarations and reports issued by the company.

Security and Crisis Management

• Taking necessary measures to protect employees, information systems, factories, and administrative facilities against potential acts of terrorism, natural disasters, and malicious activities,
• Preparing crisis management plans to ensure business continuity with minimal loss in the event of emergencies such as terrorism or natural disasters,

Implementing all necessary precautions to prevent theft or damage to company assets.

Confidentiality

• To act with the awareness that the company’s financial and commercial secrets, information that may weaken its competitive strength, personnel rights and information, and agreements with stakeholders are subject to “confidentiality,” ensuring their protection and maintaining their confidentiality.
• To refrain from sharing information acquired in the course of work and documents in their possession with unauthorised internal or external parties, under any circumstances or for any purpose, and from using such information directly or indirectly for speculative purposes.
• To avoid using non-public information about the companies they work for, their customers, or other individuals and companies they engage with for purposes other than those intended, and to refrain from sharing such information with third parties without obtaining the necessary permissions.
• To adhere strictly to company rules and instructions in compliance with the Personal Data Protection Law.

To avoid situations that could lead to a conflict of interest.

Conflict of Interest: This refers to any situation where employees possess or could possess any material or personal interests or benefits related to themselves, their relatives, friends, or associated individuals or organisations, which may influence or potentially influence their impartial execution of duties.

Employees must disclose at the time of recruitment if they hold shares in or participate in investments of another company. This matter will be addressed during job interviews with prospective candidates. Employees must notify their immediate superior of any changes over time in such situations or any matters that could be perceived as conflicts of interest.

• Employees must not exploit their position or authority to secure unjust benefits for themselves, their relatives, or third parties.
• When making personal investments, employees must take care to avoid conflicts of interest with their current workplace.
• Personal investments or activities unrelated to professional work must not hinder employees’ ability to fulfil their duties in terms of time and focus, and such situations that detract from core responsibilities must be avoided.
• Employees must inform their immediate superior if they or their close relatives are directly involved in decision-making related to the same work and are in a customer or supplier relationship with the company.
• If employees learn that their relatives hold shares or financial interests in a company involved in a commercial relationship with the organisation, they must report this to their immediate superior.

Participation in events such as sports activities, domestic/international trips, or similar invitations organised by individuals or institutions with whom there is or could be a business relationship, and which could influence decision-making or be perceived as such, requires the approval of the Board of Directors. General attendance at public conferences, receptions, promotional events, or seminars is excluded from this requirement.

In relations with private or public individuals and organisations seeking to establish or maintain a business relationship with the company:

• Employees must not accept or offer any gifts that could create an impression of irregularity, dependence, or undue influence, except for items that comply with commercial customs, traditions, or are of souvenir/promotional nature.
• Employees must not accept any benefits from suppliers, dealers, customers, group companies, or third parties that could be perceived as inappropriate, and they must decline such offers.

After leaving their position at the EAE Group, engaging in roles such as vendor, contractor, consultant, broker, agent, or distributor to the EAE Group by establishing a company or becoming a partner in one is a sensitive matter that must be handled carefully to avoid negative perceptions. During or after such a process, actions must align with the interests of the EAE Group, adhere to ethical and moral standards, and prevent conflicts of interest. In the case of a supplier who falls under this category, the responsible manager must contact the relevant EAE Group company where the supplier was previously employed and prepare a report confirming no inappropriate situation exists, informing their superior. If any inappropriate situation is identified, no commercial relationship should be established with the individual. Except for exceptional cases requiring Board of Directors approval, such business relationships should not be approved until two years after the employee has left the EAE Group to avoid negative perceptions.

Employees must acknowledge that attempting to obtain any commercial benefit by using or disclosing any confidential information belonging to our company or the EAE Group constitutes a legal offence and must strictly avoid engaging in such activities.

When deciding on an action plan for an ethical issue, you should follow the steps below and ask yourself the following questions:

• Is the relevant issue/event/behavior in compliance with the laws, rules, and traditions?
• Is the relevant issue/event/behavior balanced and fair? Would we be uncomfortable if a competitor or someone else did this?
• Would our company and stakeholders be uncomfortable if all the details of this event were revealed?
• Would you feel embarrassed or find yourself in a difficult position if others knew you engaged in this behavior?
• Could this lead to negative consequences for you or your company?
• Who else might be affected by this? (Group companies/our company and other employees, you, etc.)

The managers of EAE Elektrik A.Ş. have additional responsibilities beyond those defined for employees within the framework of the “Code of Business Ethics.” Accordingly, the managers are responsible for:

• Ensuring the creation and maintenance of a company culture and working environment that supports ethical rules,
• Setting an example with their behavior in applying ethical rules, informing employees about ethical rules,
• Supporting employees in submitting questions, complaints, and reports related to ethical rules,
• Guiding when consulted about what should be done, considering all reports, and forwarding them to the Ethics Committee as soon as necessary,
• Ensuring that the business processes under their responsibility are structured in a way that minimizes ethical risks and implementing the necessary methods and approaches to ensure compliance with ethical rules.

Employees are obligated to report to their direct managers, the Human Resources Department, or the Ethics Committee if they learn that the Company’s Code of Business Ethics or the legal regulations applicable to the Company have been violated.

Reports made to the Company will be concluded and decided upon in accordance with the Company’s internal processes and procedures. Those who violate the Code of Business Ethics or the Company’s policies and procedures will be subject to action in accordance with the “Disciplinary Management Procedure.”

Disciplinary actions will also be applied to individuals who approve, direct, or are aware of inappropriate behaviors and acts that cause violations of rules but fail to report them appropriately. Additionally, there will be no tolerance for individuals who exhibit negative behavior toward those who make complaints or assist during evaluations.

Non-compliance with the published “Code of Business Ethics” is resolved within the “Ethics Committee” of EAE Elektrik Aydınlatma A.Ş. The Ethics Committee has been established to resolve conflicts of interest and evaluate notifications regarding violations of ethical rules under EAE Elektrik Aydınlatma A.Ş.’s “Code of Business Ethics.” The Ethics Committee consists of the following members:

• Chairman – Board Member/General Manager
• Member – Factory Manager
• Member – Accounting, Finance, and HR Manager
• Member – R&D Manager
• Member – Project Manager
• Member – Quality Team Leader

The Ethics Committee conducts its activities within the framework of the following principles:

• It keeps the identity of those making notifications or complaints confidential.
• Anyone making a notification to the Ethics Committee is under the protection of the Ethics Committee, and no pressure, discrimination, or bullying can be applied to them.
• The Ethics Committee conducts the review as much as possible within the rules of confidentiality.
• The Committee has the authority to request information, documents, and evidence directly from the unit that possesses them. All collected information and documents may only be reviewed in relation to the subject of the evaluation/complaint.
• The evaluation process is documented from the outset in writing. Information, evidence, and documents are appended to the record.
• The record is signed by the chairman and members.
• The evaluation is handled urgently, and the result is reached as quickly as possible.
• The decisions made by the Committee are immediately implemented.
• Relevant departments and authorities are informed about the result.
• The chairman and members of the Committee carry out their duties independently of the managers of their respective departments and the hierarchy within the organization. They must act without being influenced, and no pressure or persuasion can be applied to them regarding the matter.
• If deemed necessary, the Committee may seek expert opinions and, during the evaluation, take measures that do not violate confidentiality principles in order to benefit from experts.
• The evaluation is conducted according to the “Disciplinary Management Procedure.”