1.INTRODUCTION

EAE Electric Lighting Inc. expects all employees to demonstrate attitudes and behaviors that will ensure the integrity of the company culture, protect and enhance the company’s reputation, and maintain the reliability of its corporate structure. All employees are obligated to comply with the “Code of Ethical Conduct.” Furthermore, all stakeholders are expected to adhere to business ethics rules and all principles that support these rules

Notifying all employees of the Code of Ethical Conduct, ensuring that employees attach the necessary importance to these rules, and showing the necessary effort and leadership to comply with these rules are among the primary duties and responsibilities of employees in management roles.

  1. EMPLOYEE RELATIONS

EAE Elektrik Aydınlatma A.Ş. values its employees and respects employee rights. In this context, our basic principles in terms of relations with employees;

  •  Making merit-based selection in recruitment and ensuring equal opportunity without discrimination,
  •  To recruit qualified employees who will carry our company into the future,
  •  Making maximum use of the talents, strength and creativity of employees,
  •  Providing equal opportunities for the training, guidance and development of employees,
  •  Rewarding success through fair and competitive wage policies and an effective and objective performance evaluation system,
  •  To increase loyalty to the company by providing equal opportunities in career opportunities and rewards,
  •  Ensuring labor peace and continuity,
  •  To provide employees with clean, healthy and safe working conditions where all kinds of occupational safety measures are taken,
  •  To create and maintain a transparent and mutually respectful working environment where cooperation and solidarity are important elements,
  •  Not allowing harassment and psychological harassment (mobbing) in the workplace,
  •  Evaluating and responding to the opinions and suggestions of employees and taking measures to increase motivation,
  •  Not to share private information about employees with third parties without the consent and knowledge of the employee, except for legal obligations,
  •  Respect for human rights.

3. EXTERNAL RELATIONS

The basic principles guiding EAE Elektrik Aydınlatma A.Ş.’s relations with its stakeholders are as follows;

 

 3.1. Communication with Stakeholders
  • Representing our company before the society and enhancing its reputation,
  •  Keeping communication channels open with stakeholders, evaluating criticism and suggestions, establishing and maintaining positive relationships,
  •  Refraining from expressing personal opinions in any criticism.
3.2. Shareholder Relations
  •  Representing our company in the eyes of the society and enhancing its reputation,
  •  To ensure that our company is managed within the framework of the principles of trust and honesty, to manage its resources, assets and working time with an awareness of efficiency by targeting sustainable growth and profitability.
3.3. State Relations
  •  To manage, record and report all business activities and the accounting system in a complete and appropriate manner in accordance with the law,
  •  To comply with all laws, rules and regulations in the countries of operation and new investments.
3.4. Social Responsibility
  •  Supporting activities that contribute to economic and social development,
  •  To show sensitivity to issues of interest to the society / country and to support the positive development of society.
3.5. Customer Relations
  •  Creating value for customers and meeting their demands and requirements at the highest level,
  •  Providing quality products and services,
  •  Creating an environment of long-term trust in relations with customers,
  •  To increase customer satisfaction in the sales and after sales process,
  •  Not providing misleading and incomplete information to customers.
3.6. Supplier and Dealer Relations
  •  Tedarikçilerle ve bayilerle iş ilişkilerinde karşılıklı değer yaratmak,
  •  Tedarikçilerle ve bayilerle iletişimi açık, doğrudan ve doğru bir şekilde yapmak,
  •  Tedarikçi ve bayi seçiminde objektif kriterler ile karar vermek,
  •  Tedarikçi ve bayi denetimlerinde ve ziyaretlerinde tedarikçi/bayi tarafından talep edilen gizlilik ve iş güvenliği kurallarına uymak,
3.7. Rakip ve Rekabet İlişkileri
  •  Except for the limits permitted by the legislation, not to enter into agreements and behaviors with competitors or other persons or organizations, directly or indirectly, which have the purpose of preventing, distorting or restricting competition, or which have or may have this effect, in any way whatsoever,
  •  Not to abuse its dominant position in a particular market, either alone or jointly with undertakings,
  •  Failing to negotiate and exchange information with competitors to jointly determine market and/or competition conditions,
  •  To avoid all kinds of meetings and transactions that may lead to or be characterized as such in meetings such as associations, chambers, professional unions, etc. and other private or professional meetings and negotiations attended on behalf of the Company.
3.8. Global Responsibility
  • To develop environmental policies and ensure their effective implementation,
  • To act in accordance with the principles set out in the United Nations Global Compact and to set an example in this regard.

4. ETHICAL BEHAVIOR RULES THAT EMPLOYEES MUST COMPLY WITH

It is the primary responsibility of all employees to ensure that our Company continues to be recognized for its professionalism, honesty and trust, and to carry it to a higher level. Within this framework, employees are expected to

  •  Always obeying 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,
  •  Our method of collecting data and legal grounds
  •  Not to gain any unfair gain from individuals and organizations for any purpose whatsoever, not to take or give bribes,
  •  To act in accordance with the relevant code of business ethics and all principles of practice that support this code in the tasks carried out,
  •  Not to engage in any behavior, statement or correspondence that would put the company under commitment unless expressly authorized,
  •  Not to engage in behaviors that may disturb and/or harm other employees,
  •  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 interest and/or political activity and benefit.
4.1. Asset and Information Management
4.1.1. Intellectual Property Rights
  •  To ensure that legal procedures are initiated in a timely manner in order to secure the intellectual property rights of newly developed products, processes and software,
  •  Avoid unauthorized use of patents, copyrights, trade secrets, trademarks, computer programs or other intellectual and industrial property rights of other companies.
4.1.2. Knowledge Management
  •  Ensure that all legal records are kept accurately and completely,
  •  Not responding to information requests from third parties, which are categorized as confidential for the company, without the approval of senior management,
  •  To exercise due diligence to ensure that the Company’s statements and reports are truthful.
4.1.3. Security and Crisis Management
  •  To take necessary measures to protect company employees, information and information systems, factories and administrative facilities against possible terrorism, natural disasters and malicious attempts,
  •  To make the necessary planning for emergency crisis management in case of terrorism, natural disasters, etc., to ensure business continuity with minimum loss in the event of a crisis,
  •  To take all kinds of measures to prevent theft or damage to Company assets.
4.1.4. Privacy
  •  To act with the awareness that the financial and trade secrets of the company, information that will weaken the competitive power of the company, personnel rights and information, agreements with stakeholders are within the framework of “confidentiality”, and to ensure their protection and confidentiality,
  •  Not to share the information learned as a business requirement and the documents they possess with unauthorized authorities inside and outside the company for any purpose whatsoever, and not to use them directly or indirectly for speculative purposes,
  •  Not to use non-public information about the companies they work for, their customers and other persons and companies they do business with for any purpose other than the intended purpose, and not to share it with third parties without obtaining the necessary permissions.
  •  Not to go beyond the rules and instructions of the company in accordance with the Law on the Protection of Personal Data.
4.2. Avoiding Conflicts of Interest

Not to be in situations that may cause conflict of interest.

Conflict of Interest: It refers to any kind of benefit provided to the employees, their relatives, friends or persons or organizations with whom they have relations, and any material or any personal interest related to them, which affects or may affect the impartial performance of their duties.

4.2.1. Not making transactions in favor of oneself or one’s relatives

Employees are required to declare their shareholding or participation in investments in another company, if any, at the time of their first employment. This issue will be questioned during job interviews with candidates. Employees shall notify their senior supervisors of any changes that may arise in these situations over time and similar issues that may be perceived as a conflict of interest.

  •  Not to gain unfair advantage in favor of himself/herself, his/her relatives or third parties by taking advantage of his/her title and authority,
  •  In personal investments to be made, taking care not to fall into a conflict of interest situation with the current organization,
  •  Taking care to ensure that personal investments or any other non-business activities do not interfere with the time and attention available for the performance of his/her current duties, and avoiding such situations that interfere with the focus on the main tasks,
  •  To inform the immediate supervisor in case the employee and the persons who are in the first-degree decision-making position regarding the same business in the customer or supplier company are first-degree relatives,
  •  Informing his/her immediate supervisor in case of learning that his/her relatives have shares or material interests in another company with which he/she has a commercial relationship.
4.2.2. Participation in Representation and Organization Invitations

Participation in invitations such as conferences, receptions, promotional events, seminars, etc. that are open to general participation organized by persons or institutions with whom the Company has or has the potential to have a business relationship, as well as sports activities, domestic/foreign trips, etc. that are or may be perceived as influential in decision-making are subject to the approval of the Board of Directors.

4.2.3. Receiving and Giving Gifts

In the conduct of relations with private or public persons and organizations wishing to establish or maintain a business relationship with the Company;

  •  Not to accept or offer any gift that creates the impression of the existence of an irregularity, that may cause or be perceived to cause a relationship of dependency, other than those given in accordance with commercial traditions, customs and traditions or souvenir / promotional materials,
  •  Not accepting any benefits from suppliers, dealers, customers, group companies or third parties that may be perceived as inappropriate, and not accepting them when offered.
4.2.4. Business with EAE Group by Leavers

Establishing a company or becoming a partner in a company after leaving EAE Group and doing business with EAE Group companies as a salesman, contractor, consultant, broker, representative, dealer or in similar ways is a very sensitive issue that may create negative perceptions. Before or after such a process, it is necessary to act within the framework of EAE Group’s interests, to comply with moral and ethical rules, and not to allow conflicts of interest before or after the process. For a supplier in this situation, the relevant manager is required to contact the EAE Group company where the supplier has previously worked, prepare a report that there is no inappropriate situation and inform his/her immediate supervisor. If there is an inappropriate situation, no commercial relationship should be established with the relevant person. Except in exceptional cases requiring the approval of the Board of Directors, such commercial relations should not be approved until 2 years after the employee has left EAE Group in order to prevent negative perceptions.

4.2.5. Insider Trading

Knowing that it is a legal offense to try to obtain any commercial benefit by using or giving any confidential information belonging to our Company and EAE Group to third parties and never attempting to do so.

  1. OCCUPATIONAL HEALTH AND SAFETY

Our company aims to ensure full occupational health and safety at work and on the job.

  •  Employees act in accordance with the rules and instructions set for this purpose and take the necessary measures.
  •  Employees shall not keep in the workplace any item or substance that is illegal or that poses a danger to the workplace and/or employees,
  •  Employees shall not possess drugs, addictive substances, substances that restrict or eliminate mental or physical faculties in the workplace, except for those kept in accordance with a valid medical report, and shall not work at the workplace or within the scope of work while under the influence of such substances.

 

6. PROHIBITION OF POLITICAL ACTIVITY

Our company does not make donations to political parties, politicians or political candidates. Demonstrations, propaganda and similar activities are not permitted within the boundaries of the workplace. Company resources (such as vehicles, computers, e-mails) are not allocated for political activities.

  1. APPLICATION PRINCIPLES

Since EAE Elektrik Aydınlatma also operates in international markets, company operations may be subject to the laws and regulations of different countries. When there are question marks regarding the ethics of doing business in different countries, the established regulations in the country where the work is carried out should be followed first. If monitoring the regulations in the country and/or countries where the work will be carried out is of a nature that may create unfavorable results in terms of the ethical values adopted by EAE Elektrik Aydınlatma A.Ş., which will operate on the international platform, then we try to find solutions within the ethical rules and procedures we have.

7.1. Ways and Methods to be Followed in Making Ethical Decisions

You should follow the steps below and ask yourself these questions to guide you in deciding on a course of action on an ethical issue:

  •  Is the relevant issue/event/behavior in line with laws, rules and customs?
  •  Is the issue / event / behavior balanced and fair? Would we feel uncomfortable if a competitor / someone else did it?
  •  Would our company and our stakeholders feel uncomfortable if all the details of this incident were made public?
  •  Would you feel embarrassed or ashamed if others knew you had done this?
  •  Could it have negative consequences for you or your Company?
  •  Who else may be affected (Group companies / our company and other employees within the company, you, etc.)
  •  
7.2. Responsibilities of Managers

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

  •  Ensuring the creation and maintenance of a corporate culture and working environment that supports ethical rules,
  •  Setting an example for the implementation of ethical rules with their behaviors and informing their employees about ethical rules,
  •  Supporting employees in communicating their questions, complaints and notifications regarding ethical rules,
  •  Providing guidance on what to do when consulted, taking into account all notifications received and forwarding them to the Ethics Committee as soon as possible when deemed necessary,
  •  Ensuring that the business processes under his/her responsibility are structured in a way to minimize the risks related to ethical issues and applying the necessary methods and approaches to ensure compliance with ethical rules,

is responsible.

7.3. Notification and Resolution of Non-Compliance with the Code of Ethics

If employees learn that the Company’s Code of Business Ethics or the legal regulations to which the Company is subject are violated, they are obliged to report this to their direct managers or the Human Resources Department or the Ethics Committee.

Notifications made to the Company are finalized and resolved in line with the Company’s internal operations and procedures. Those who violate the Code of Business Ethics or Company policies and procedures are dealt with in accordance with the “Disciplinary Management Procedure”.

Disciplinary management sanctions will also be imposed on those who approve, direct or have knowledge of inappropriate behavior and rule-breaking acts and fail to report them appropriately. In addition, there is also no tolerance for those who behave in a negative manner towards those who make complaints and notifications or assist in the evaluation process.

7.4. Ethics Committee

Non-compliance with the announced “Code of Business Ethics” is resolved within EAE Elektrik Aydınlatma A.Ş. “Ethics Committee”. The Ethics Committee was established to resolve conflicts of interest within the scope of EAE Elektrik Aydınlatma A.Ş. “Code of Business Ethics” and to evaluate the notifications communicated to it regarding violations of ethical rules. The Ethics Committee consists of the following persons:

  •  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
7.5. Ethics Committee Working Principles

The Ethics Committee conducts its activities within the framework of the principles set out below:

  •  Keeps the identity of notifications and complaints and the identity of those making the notification or complaint confidential.
  •  Everyone who notifies the Ethics Committee is under the protection of the Ethics Committee due to these notifications and cannot be subjected to pressure, discrimination or mobbing.
  •  The Ethics Committee conducts the evaluation as confidential as possible.
  •  It is authorized to request the information, documents and evidence related to the review directly from the existing unit. It may examine all kinds of information and documents it obtains only limited to the subject of the evaluation / complaint.
  •  The evaluation process is recorded in a written report from the beginning. Information, evidence and documents are attached to the minutes.
  •  The minutes are signed by the chairperson and members.
  •  The assessment is handled in an expeditious manner and the outcome is reached as quickly as possible.
  •  The decisions taken by the Board shall be implemented immediately.
  •  Relevant departments and authorities are informed about the outcome.
  •  The chairman and members of the Board act independently and unaffected by their department managers and the hierarchy within the organization while fulfilling their duties on this issue. They may not be pressured or advised on the matter.
  •  The Board may seek expert opinion if it deems necessary and may benefit from experts by taking measures not to violate the principles of confidentiality during the evaluation.
  •  The evaluation is carried out according to the “Discipline Management Procedure”.

 

 

  • OUR HUMAN RIGHTS POLICY

Introduction

The purpose of the Human Rights Policy is to create a guideline that reflects our approach to fundamental human rights as EAE Aydınlatma A.Ş. in line with the United Nations Sustainable Development Goals, to emphasize the respect we show for human rights and the value we give to all our employees and our value chain, and to build a human rights-oriented approach in our relations with all stakeholders.

Our policy is also integrated with our Code of Business Ethics, corporate policies and corporate values and is applied throughout our own operations and our entire value chain. Our internal practices refer to the aforementioned EAE Lighting A.Ş. Human Rights Policy, Discipline Management Procedure and Code of Business Ethics Handbook.

Our employees and managers in the regions where we operate are obliged to act in accordance with this policy, to implement and support the relevant procedures and controls of EAE Lighting A.Ş. in line with the requirements in this Policy. We expect all our stakeholders and value chain with whom we are in a relationship of supplying goods or services to act in compliance with the principles and principles in this policy to the extent applicable to the relevant party and transaction, and we take the necessary steps to ensure this.

EAE Lighting A.Ş. as “UN Universal Declaration of Human Rights (UDHR) (1948)” and the principles we have followed “UN Global Compact (UNGC) (2000)” we are guided by an approach that respects universal human rights towards our employees, all stakeholders and other communities affected by our products or services.

We consider human rights among the most important of our ethical principles and expect all our stakeholders to act in accordance with these principles and EAE Lighting A.Ş. Human Rights Policy. We guarantee human rights in the contracts we make with all our stakeholders and value chain; we include provisions regarding full compliance with the principles and principles in this Policy, and that the employees of our stakeholders internalize and act in accordance with these principles and principles, and we encourage them in this regard.

We provide corporate training and capacity building opportunities for our employees on human rights. We also envision to contribute to the capacity development of our stakeholders with whom we have business relations.

The international standards and principles we prioritize in relation to Human Rights are set out below:

  • UN Universal Declaration of Human Rights (UDHR) (1948)
  • UN Global Compact (UNGC) (2000)
  • UN Guiding Principles on Business and Human Rights (2011)
  • ILO Declaration on Fundamental Principles and Rights at Work (1998)
  • OECD Guidelines for Multinational Enterprises (2011)
  • Women’s Empowerment Principles (WEPs) (2011)

Our basic principle is to create a healthy, safe, fair, positive and professional working environment for our employees, to ensure its continuity and to observe all the rights of our employees.

As EAE Lighting, we take into account the special circumstances of groups whose rights are described in more detail in UN documents (indigenous peoples, women, ethnic, religious and linguistic minorities, children, people with disabilities, refugee/migrant workers and their families), as stated in the “UN Guiding Principles on Business and Human Rights (2011)”.

Diversity, Inclusion and Equal Opportunity

  • Demonstrate an inclusive, diversity-oriented, fair, ethical and egalitarian attitude without discriminating between our employees in the work environment or in recruitment, placement, termination, training, career, promotion, assignment, discipline, wage management and benefit processes, without discriminating religion, language, race, nationality, ethnic origin, belief, sect, color, age, sexual orientation, gender, marital status, political opinion, disadvantage and any legally protected characteristic,
  • To be the most preferred employer for all candidates who are committed to their work and can add value, and to be an employer that protects the rights of its employees,
  • Kendi operasyonlarımız ve değer zincirimiz boyunca ayrımcılığın hiçbir türüne kesinlikle müsamaha göstermemeyi,
  • Çalışanlarımızla sürekli diyalog içinde olmayı, çalışanlarımızı ilgilendirebilecek tüm konuları düzenli olarak kendileriyle paylaşmayı ve katılımcı bir yaklaşımla çalışanlarımızın fikirlerini özgürce ifade edebildikleri adil, sağlıklı ve güvenli çalışma ortamları yaratmayı,
  • To evaluate our employees in positions where they can utilize their potential in a truly productive manner and create contribution and value in achieving the main goals of the company,

 

Prevention of Child Labor and Forced/Compulsory Labor

  • We strongly oppose child labor and all forms of forced and compulsory labor, including modern slavery, bonded labor and human trafficking, which cause physical and psychological harm to children and deprive them of their right to education at any stage of our activities,
  • Ensure that our stakeholders also develop procedures to avoid child labor and forced and compulsory labor practices,

 

Zero Tolerance for Harassment and Violence

  • To provide our employees with a safe working environment, free from any kind of abuse, misconduct, intimidation, maltreatment or physical, verbal, sexual/psychological harassment, bullying, threats and violence and to take all necessary measures and support them with procedures,
  • Set remuneration competitively according to the sectoral and local labor market and pay all wages, including benefits, in accordance with applicable laws and regulations,
  • Full and correct utilization of the personal rights of our employees,
  • Ensure that our stakeholders develop procedures to apply similar approaches to their employees,

 

Personal/Professional Development

  • To see human capital as a valuable resource, to maintain a long-term business relationship with our employees by continuously investing in their talents, potential and personal/professional development through internal and external trainings so that they can develop themselves in the best way and do their jobs better,

Occupational Health and Safety

  • In accordance with the Occupational Health and Safety Legislation, to provide a healthy and safe working environment for our employees and our Stakeholders who are in our work areas for any reason, to take the necessary safety measures and to implement regular training and information activities in line with our “zero accident” target,

Working Life and Data Privacy

  • To comply with national/international regulations and digital privacy, data confidentiality and security standards for the protection of personal data of our Employees and Stakeholders, as well as confidential information (commercial information, technical data, financial data, production data, customer information, personal information, product information, equipment and application information, technical formulas and drawings, system and program information, procurement information, engineering information, regulations, business plans and all information that the company does not disclose to the public, including but not limited to),

Respect for the Environment and Society

  • In line with our sustainable growth and green transformation goals, analyzing the environmental impacts of our investment projects in accordance with national/international legislation, with the awareness of our responsibility towards the environment and society,
  • Aware of the potential impact of land and natural resource use on human rights throughout our value chain, we aim to address this issue through specific policies and practices. In line with our corporate policy, we focus on the efficient use of energy, water, and raw materials, as well as the preference for renewable resources, to reduce harm to the environment and health across our value chain.
  • Identifying areas of high water stress within our operations and production activities, including the supply chain, reducing water usage and the amount of discharged wastewater on a resource basis, and working to increase water use efficiency.
  • We consider our business as part of society and respect the rights of communities affected by our activities. We aim to address local issues in the most appropriate way at the local level and, when necessary, engage with civil society representatives on human rights matters.

 

Complaints Mechanism

  • We will make arrangements through contracts to monitor and ensure that international legal requirements regarding human rights in supply chain practices are upheld by all our employees and stakeholders. Additionally, we will effectively use the existing whistleblower/complaints hotline and the email address of EAE Lighting Inc., [email protected], as part of our mechanisms.

We commit.

Our Human Rights Policy was published on April 27, 2023, with the approval of the General Manager of EAE Lighting Inc. This policy is regularly reviewed by the “EAE Lighting Inc. Ethics Board” at least once a year, focusing on current requirements and changes in our operational conditions. Necessary updates/revisions are approved by the General Manager upon the proposal of the “EAE Lighting Inc. Ethics Board” and come into effect. The General Manager is ultimately responsible for ensuring compliance with this policy and for the regular monitoring of potential violations and suspicious situations within the scope of improvements.

Any employee who believes there is a conflict between the language of the policy and our activities, has questions about this policy, or wishes to report a potential violation of this policy confidentially, can communicate their concerns to the “EAE Lighting Inc. Ethics Board” (to any of the board members). The General Accounting & HR Team Leader performs the secretariat duties of the “EAE Lighting Inc. Ethics Board.” The manager of the relevant department may be invited to the Ethics Board on a case-by-case basis.

We effectively use our existing whistleblower/complaints mechanism to ensure compliance with the Human Rights Policy and to regularly monitor potential violations and suspicious situations within the scope of improvements. We strive to evaluate the business processes of our stakeholders, from whom we procure goods/services, in line with the commitments made by international organizations on human rights. We maintain continuous interaction with our stakeholders and value chain to agree on ways to prevent and/or mitigate the risks and impacts related to human rights issues.

We set annual goals/objectives to prevent and/or mitigate risks and impacts related to human rights issues throughout our value chain, and we track progress over time (through internal and external programs and audits).

Feedback regarding this Policy, as well as potential Policy violations and non-compliance, can be reported to the “EAE Lighting Inc. Ethics Board” via sealed envelope with attachments or through email ([email protected]).

In the event of identifying violations and suspicious situations that contradict the principles and provisions in this Policy, various disciplinary sanctions may be applied in accordance with the relevant legal provisions, which may include requesting the employee’s resignation if necessary. Disciplinary sanctions will also be applied to individuals who approve, direct, or are aware of such inappropriate behaviors and violations but fail to report them appropriately.

Our Human Rights Policy is made publicly available to all our stakeholders through our corporate website, and is also accessible to all our employees through our corporate intranet site/QDMS.

  • OUR ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Introduction

The purpose of the Anti-Bribery and Anti-Corruption Policy is to outline the principles and practices of EAE Lighting Inc. in the fight against bribery and corruption and to ensure clear communication of these principles. With this policy, we aim to identify, reduce, and manage bribery and corruption risks in compliance with legal regulations, ethical and professional principles, and in accordance with the universal legal rules guided by the “UN Global Compact (UNGC) (2000)” that we follow.

This Policy is fully aligned with the EAE Lighting Inc. Code of Business Ethics, company policies, and Corporate Values, and it is implemented throughout our operations and entire value chain. Our internal practices reference this Anti-Bribery and Anti-Corruption Policy and our Code of Business Ethics.

Our employees and managers in the regions where we operate are responsible for acting in accordance with this policy and implementing and supporting EAE Lighting Inc.’s relevant procedures and controls in line with the requirements of this policy. We also expect all our stakeholders and our entire value chain, with whom we have goods or services procurement relationships, to adhere to the principles and provisions in this policy to the extent applicable to the relevant party and transaction, and we take the necessary steps to ensure this compliance.

Conflict of Interest: It refers to any material or moral interest that prevents employees from performing their duties impartially or creates the perception that it does.

Ethics Board: The Ethics Board operates under the General Manager and is responsible for deciding on actions to be taken in cases of complaints and reports regarding violations of the Code of Business Ethics.

Gift: Anything of economic value or not, accepted directly or indirectly, that affects or may affect an employee’s impartiality, performance, decision, or ability to perform their duty.

Stakeholders:They are the governance components involved in economic, social, and environmental interactions throughout the value chain.

Bribery: It is providing a material or immaterial benefit directly or indirectly to oneself, the requesting party, or another person they may indicate, in exchange for an oral/written agreement, in order to influence a person to perform an action outside the normal course of business or in violation of the requirements of their duty, such as performing, not performing, delaying, or accelerating a task, either directly or through intermediaries.

Corruption:Corruption is the abuse of one’s position and authority for the purpose of obtaining material or immaterial gain, either directly or indirectly, by deviating from the lawful performance of duties.

At EAE Lighting Inc., we are committed to conducting our operations in alignment with our ethical values. Our “Code of Business Ethics” document regulates the fundamental ethical behavior rules of our company and has been created to ensure that EAE Lighting Inc. develops in compliance with national and international laws and ethical standards. As per our Ethical Rules, EAE…

EAE Lighting Inc. aims for full compliance with the principles and provisions outlined in this policy; no form of bribery or corruption is tolerated, regardless of the objective. This EAE Lighting Inc. Anti-Bribery and Anti-Corruption Policy has been implemented as a reflection of the importance given to this issue.

We consider the fight against bribery and corruption as one of the most important ethical principles and expect all our stakeholders to act in accordance with these principles and the EAE Lighting Inc. Anti-Corruption Policy. In all contracts with our stakeholders, we ensure the inclusion of anti-bribery and anti-corruption measures; we include provisions for full compliance with the principles and provisions of this policy, encourage our stakeholders to internalize these principles, and ensure that their employees act accordingly.

To increase the awareness and competence of our employees and stakeholders in the fight against bribery and corruption, and to ensure the internalization of the principles and provisions outlined in this Policy, e-learning practices are developed with the support of the EAE Lighting Inc. Quality Unit and are regularly implemented every year.

All our employees and stakeholders are obligated to act in accordance with the principles and provisions outlined in this Policy, relevant national/international legal regulations, and all anti-bribery and anti-corruption laws in force. Our employees sign a document stating that they accept compliance with these policy provisions and the consequences of non-compliance.

In the event of identifying violations and suspicious situations that contradict the principles and provisions in this policy, various disciplinary sanctions may be applied in accordance with the relevant legal provisions, which may include requesting the employee’s resignation if necessary. Disciplinary sanctions will also be applied to individuals who approve, direct, or are aware of such inappropriate behaviors and violations but fail to report them appropriately.

It is not acceptable for our employees or stakeholders to face any retaliation for reporting violations of the principles and provisions in this policy, refusing to participate in a bribery or corruption incident, or expressing concerns about potential future bribery and corruption actions.

  • To monitor and ensure that all our employees and stakeholders comply with national/international legal requirements regarding anti-bribery and anti-corruption in supply chain practices, we make arrangements through contracts and effectively utilize our existing whistleblowing/complaint mechanisms at [email protected].

Our Anti-Bribery and Anti-Corruption Policy was published with the approval of the General Manager of EAE Lighting Inc. on April 17, 2023. This policy is reviewed regularly by the “EAE Lighting Inc. Ethics Board” at least once a year, focusing on updated requirements and changes in our operational conditions. Necessary updates/revisions are approved by the General Manager upon the suggestion of the “EAE Lighting Inc. Ethics Board” and come into effect. The General Manager is ultimately responsible for ensuring compliance with this policy and for the regular monitoring of any potential violations or suspicious situations as part of improvements.

Any employee or stakeholder who believes there is a conflict between the language of the policy and our activities, has questions about this policy, or wishes to report a potential violation of this policy confidentially, can communicate their concerns to the “EAE Lighting Inc. Ethics Board.”

An employee can communicate any questions or concerns to the “EAE Lighting Inc. Ethics Board” (to one of its members). The “EAE Lighting Inc. Ethics Board” is supported by the General Accounting and HR Team Leader, who performs the secretariat duties. Based on the issue, the General Manager or the relevant manager may invite the Ethics Board to discuss the matter. To ensure compliance with the policy and the regular monitoring of potential violations or suspicious situations as part of improvements, we actively utilize our existing whistleblowing/complaint mechanisms and make efforts to evaluate the business processes of our stakeholders, from whom we procure goods/services, within the framework of their commitments to international organizations regarding human rights.

Feedback regarding this policy, as well as potential policy violations and inconsistencies, can be reported to the “EAE Lighting Inc. Ethics Board” through the submission of a closed envelope with an ethics notification form and attachments, or via email ([email protected]). Our business processes include effective internal control mechanisms to prevent potential bribery and corruption risks.

Our Bribery and Corruption Policy is made publicly available to all stakeholders through our corporate website, as well as accessible to all employees via our corporate intranet site/QDMS.

  • Our Supplier Code of Conduct

Introduction

At EAE Lighting Inc., our reputation is shaped not only by our employees but also by the suppliers we collaborate with. In order to build a sustainable future and conduct our business in accordance with national/international ethical and compliance standards, we aim to establish sustainable and long-lasting business relationships with suppliers who share our common values and embrace ethical principles and guidelines.

In this context, the “EAE Aydınlatma A.Ş. Supplier Code of Conduct” that we have prepared outlines the minimum standards that we expect our suppliers to comply with in their commercial relationships with our company. These rules are non-negotiable and are aligned with internationally recognized environmental, social, and ethical standards. Acceptance of these rules is a prerequisite for every EAE Aydınlatma A.Ş. supply contract and order.

The “EAE Aydınlatma A.Ş. Supplier Code of Conduct” is aligned with our Business Ethics Rules, Company Policies, and Corporate Values, and is applied throughout our entire supply chain.

All suppliers establishing business relations with our company are responsible for ensuring that their companies, employees, suppliers, and subcontractors understand and comply with these rules.

Our suppliers undertake to ensure that they, their employees, subcontractors, and suppliers will act in accordance with the following rules.

Compliance with Laws and Policies

Our suppliers are responsible for being aware of and complying with the applicable national and international laws, regulations, and other official provisions (such as commercial, export, import regulations, etc.) in the countries where they operate. They are also responsible for fully adhering to the requirements of the contracts signed with them.

Our suppliers are expected to have effective and functioning management systems in place to ensure compliance with legal regulations and the rules outlined in this document.

Our suppliers are required to comply with all of our corporate policies and procedures related to our operations, including but not limited to Integrated Management Systems, Sustainability, Human Rights, Anti-Bribery and Anti-Corruption, and Corporate Social Responsibility Policies.

Honest and Ethical Business Practices

We expect our suppliers to conduct their activities in a fair, honest, ethical, transparent, and legally compliant manner, in alignment with EAE Aydınlatma A.Ş. Supplier Code of Conduct, Code of Business Ethics, our company policies, and Corporate Values.

Universal Human Rights and Working Conditions

We adopt an understanding that respects universal human rights towards our employees, all our suppliers and other communities affected by our activities, products or services. We consider human rights among the most important of our ethical principles and ask all our suppliers to act in accordance with these principles and EAE Lighting A.Ş. Human Rights Policy. The international standards and principles that we prioritize regarding Human Rights and expect our suppliers to comply with are listed below:

  • UN Universal Declaration of Human Rights (UDHR) (1948)
  • UN Global Compact (UNGC) (2000)
  • UN Guiding Principles on Business and Human Rights (2011)
  • ILO Declaration on Fundamental Principles and Rights at Work (1998)
  • OECD Guidelines for Multinational Enterprises (2011)
  • Women’s Empowerment Principles (WEPs) (2011)

 

Diversity, Inclusion and Equal Opportunity and Work Environment:We adopt an inclusive, diversity-conscious, fair, ethical and egalitarian attitude without discriminating between our employees in the workplace or in recruitment, placement, termination, training, career, promotion, assignment, discipline, wage management and benefit processes, regardless of religion, language, race, nationality, ethnic origin, belief, sect, color, age, sexual orientation, gender, marital status, political opinion, disadvantage and any legally protected characteristic. To ensure a successful supply chain, we expect our suppliers to share this commitment. Our suppliers must not tolerate any form of discrimination in their operations and throughout the value chain. They should create a healthy, safe, fair, positive and professional working environment for their employees, and their basic principles should be to ensure the continuity of this environment and to observe all the rights of their employees. Pay attention to gender equality in all their activities, develop practices to support female employees in business life and encourage their sub-suppliers and contractors to adopt these practices.

Prevention of Child Labor and Forced/Compulsory Labor:Our suppliers must strongly oppose child labor in their operations, which causes physical and psychological harm to children and deprives them of their right to education, and all forms of forced and compulsory labor, including modern slavery, bonded labor and human trafficking.

Working Hours and Remuneration: We expect our suppliers to observe compliance with legal working hours, working conditions and overtime provisions set by laws and regulations applicable in the regions where they operate. They must set remuneration competitively according to the industry and local labor market and pay all wages, including benefits, in accordance with applicable laws and regulations.

Zero Tolerance for Harassment and Violence: Our suppliers must provide their employees with a safe working environment, free from any kind of abuse, exploitation, intimidation, maltreatment or physical, verbal, sexual/psychological harassment, bullying, threats and violence, and must take all necessary measures and support them with procedures.

Personal/Professional Development:Our suppliers should see human capital as a valuable resource and invest in the skills, potential and personal/professional development of their employees through internal and external trainings in order for them to develop themselves in the best way and do their jobs better.

Occupational Health and Safety:In line with the Occupational Health and Safety Legislation, our suppliers must provide a healthy and safe working environment for their employees and those who are in their work areas for any reason, take the necessary safety measures and implement regular training and information activities in line with the “zero accident” target.

Working Life and Data Privacy: Our suppliers must respect the right to privacy and comply with national/international regulations and digital privacy, data confidentiality and security standards to protect the personal data of their employees and stakeholders, as well as confidential information (including, but not limited to, commercial information, technical data, financial data, production data, customer information, personal information, product information, equipment and application information, technical formulas and drawings, system and program information, procurement information, engineering information, regulations, business plans and all information that the company does not make public).

Respect for the Environment and Society:In line with our sustainable growth and green transformation goals, and with the awareness of our responsibility towards the environment and society, we expect our suppliers to take into account the impacts of climate change on economic, environmental and social welfare and the associated risks and opportunities, and to contribute to the global struggle to transition to a low carbon economy. In line with our country’s 2053 net-zero emission target, green development vision and circular economy principles, our suppliers should show the necessary sensitivity in energy/resource efficiency, renewable energy, recycling and recovery, aim to continuously reduce/prevent waste, emissions and discharges arising from their activities, products and services, and not harm the environment and health due to their operational activities. They should also aim to provide added value to the society in which they operate by developing social responsibility projects that support sustainable development. They should procure the energy resources they use in a way that contributes to the environment as much as possible and ensure the use of renewable energy.

Trade Controls

Our suppliers must ensure that their operations comply with the terms of their export licenses and applicable regulations. Our suppliers who transport and/or handle products subject to export/import controls or sanctions are responsible for properly understanding and applying relevant trade laws and regulations and company rules. Our suppliers must keep up to date with and comply with frequently changing sanctions, export restrictions, economic sanctions, boycott and embargo laws.

Anti-Bribery and Anti-Corruption

We consider anti-bribery and anti-corruption among the most important of our ethical principles, and we do not tolerate any anti-competitive behavior or any actions related to money laundering, bribery and corruption throughout our own operations and value chain. We expect all our suppliers to act in accordance with EAE Lighting A.Ş. Anti-Bribery and Anti-Corruption Policy.

Media and Social Media

We expect our suppliers not to share any positive or negative comments, information and documents related to EAE Aydınlatma A.Ş. or attributable to EAE Aydınlatma A.Ş. on visual/written media channels and social media. Our suppliers should not share any confidential or strategic information, documents and visuals, including EAE Aydınlatma A.Ş.’s trade secrets, in their personal accounts on social media and networks, should refrain from words and attitudes that disparage EAE Aydınlatma A.Ş. services, customers, suppliers or competitors, and should not respond to media or other organizations’ questions about EAE Aydınlatma A.Ş. and should not make any comments on behalf of EAE Aydınlatma A.Ş. Our suppliers must consult with the Plant Manager and obtain written approval before making any statement regarding their work with EAE Lighting.

Supplier Audit and Evaluation Process

Our suppliers must provide accurate, transparent and open information on the issues we audit and question them about. They should focus on the issues we have asked, especially within the scope of sustainability and integrated management systems, and ensure their own development. Complete the Non-Compliance reports submitted after the audit within the time period given to them and submit them to EAE Lighting in an accurate, transparent and understandable manner. The supplier must not make any non-compliance in this process.

Our Supplier Code of Conduct was published with the approval of the General Manager on April 27, 2023. The said Code is regularly reviewed by the “Ethics Committee” at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of the “Ethics Committee” and enter into force. The General Manager is responsible at the highest level for ensuring compliance with the Rules in this document and ensuring regular follow-up of possible violations and suspicious situations within the scope of improvements.

Feedback regarding the Supplier Code of Conduct and possible violations of legal regulations or Rules and non-compliance must be reported to the “Ethics Committee” via e-mail ([email protected]). The secretariat duty of the “Ethics Committee” is carried out by the General Accounting & I&I Team Leader. The relevant manager may be invited to the Ethics Committee on a subject basis.

In order to confirm that our suppliers act in accordance with the content of our Supplier Code of Conduct, EAE Lighting A.Ş. may conduct on-site or remote, announced or unannounced audits to our suppliers, and periodically request information/documents from our suppliers. Our suppliers also accept that EAE Lighting A.Ş. has the right to request and audit such information/documents. Our suppliers are obliged to submit all relevant documents requested from them to EAE Lighting within 3 days at the latest.

In the event that a possible non-compliance is detected during the audits to be carried out on our suppliers;

  • EAE Aydınlatma A.Ş. reserves the right to unilaterally terminate our business relationship with our suppliers who violate the principles and principles in our Supplier Code of Conduct.
  • We may require our suppliers to implement an action plan to address the non-compliance and may conduct follow-up audits to ensure that the actions set out in the action plan are carried out.

EAE Aydınlatma A.Ş. Supplier Code of Conduct is made publicly available to all our stakeholders through our corporate website, as well as to all our employees through our corporate intranet site/QDMS.

  • CORPORATE SOCIAL RESPONSIBILITY POLICY

Introduction

“EAE Aydınlatma A.Ş. Corporate Social Responsibility Policy” emphasizes our basic principles and principles at the center of corporate social responsibility and the importance and priority of the issue for us.

This Policy is also integrated with our Code of Business Ethics, Company Policy and Corporate Values and is applied throughout our own operations and our entire value chain. Our internal practices refer to the Corporate Social Responsibility Policy and Code of Business Ethics document of our company in question.

All our employees and managers are obliged to act in accordance with this policy, to implement and support the relevant procedures and controls of EAE Aydınlatma A.Ş. in line with the requirements in this policy. We expect all our stakeholders with whom we are in a relationship of supplying goods or services to act in compliance with the principles and principles in this policy to the extent applicable to the relevant party and transaction, and we take the necessary steps to ensure this.

  1. Definitions:

Stakeholders, governance components that interact economically, socially and environmentally along the value chain.

Social Investment,Strategic collaborations and interactions that we, as EAE Aydınlatma A.Ş., establish with real-legal entities in order to carry out studies on environmental and social/societal issues in order to provide long-term corporate benefits and enhance the reputation of the company.

  1. Principles and Guidelines:

The principles and guidelines in EAE Lighting’s Corporate Social Responsibility Policy are presented below:

  • Our Responsibilities Towards Our Employees
  • As EAE Lighting, we meticulously ensure that the rights of our employees are respected and we encourage continuous dialog with our employees.
  • We are also committed, without limitation, to comply with the following rules, even if not required by applicable law.
    • Forced labor, forced labor or child labor, directly or indirectly or through subcontractors working in our workplace, is prohibited.
    • There is no discrimination or mobbing against our employees during the recruitment process, while they are working or when the employment relationship ends.
    • When hiring and promoting our employees, we base the basic principle on the qualifications and skills required by the job and the performance of the individual.
    • We evaluate our employees in positions where they can utilize their potential in a truly productive manner and where they can contribute and create value in achieving our company’s main goals.
    • In order to enable our employees to perform their jobs in the best way possible, we inform them about the company’s vision, mission, strategy, policies, targets, objectives, operational results, and their duties and responsibilities, and we regularly share with them all issues that may be of interest to our employees.
    • We ensure that the personal rights of all employees are fully and properly utilized; we approach our employees honestly, equitably and fairly, and ensure that they work in a non-discriminatory, safe and healthy work environment.
    • We provide the necessary training and development opportunities for our employees to develop themselves in the best way possible and to do their jobs better.
    • Etik kurallara uygun davranan ve kendisinden beklentileri karşılayan çalışanlarımızı şirkete yarattıkları değer nispetinde adil bir biçimde ücretlendiriyoruz.
  • Our Responsibilities to the Environment and Society
  • We consider acting with corporate social responsibility awareness throughout all our operational activities and value chain as one of the fundamental and unchanging elements of our corporate governance approach.
  • With our vision of becoming the leading luminaire manufacturer in the lighting industry, we aim to create long-term value for all our stakeholders, to develop R&D-oriented, high-quality, energy-friendly, sustainable products with high recycling rates through innovative technologies and methods, and to be ready for green transformation while securing product quality, efficiency and safety with international standards.
  • In order to improve the quality of life of the society and create value for all our stakeholders, we support sustainable development, pursue policies that respect the environment and society, and strive to support various projects (education and training, environment, technology, sports, arts, local economy, contribution to healthy living, social investment projects, etc.) prepared with social, environmental and cultural content. In addition, we are sensitive to the realization of all our social responsibility/social development projects in line with the principles of sustainability, transparency, participation and respect for human rights.
  • We expect our employees and stakeholders to contribute to any initiative that will support the development and spread of environmentally friendly technologies and raise environmental awareness. We take care to fulfill our social and environmental responsibilities towards society in cooperation with our employees and all our stakeholders.
  • We support our employees to volunteer in appropriate social and community activities in line with corporate social responsibility awareness.
  • We develop approaches to ensure that our suppliers also act with environmental and social responsibility awareness and we attach importance to the implementation of these approaches.
  • We are sensitive to the traditions, customs and cultures of Turkey and act in compliance with all legal regulations and national/international standards.
  • We benefit the environment by providing renewable energy for the electricity we use within our company, produce energy-efficient products and explain these activities through our website (https://www.eaeaydinlatma.com), contributing to social awareness.
  • Environment Day Event

Every year on June 5, Environment Day, a tree planting event is organized with company employees. In addition, materials that can be used to reduce the amount of waste are given to company employees for the awareness of Environment Day. The aim of this event is to contribute to nature and to create environmental awareness among company employees.

Our Corporate Social Responsibility Policy was published with the approval of the General Manager on April 27, 2023. This policy is regularly reviewed by our Sustainability Committee at least once a year, focusing on current requirements and changes in our operating conditions. Updates/revisions deemed necessary are approved by the General Manager upon the recommendation of the Sustainability Committee and enter into force.

EAE Aydınlatma A.Ş. Corporate Social Responsibility Policy is made available to all our stakeholders through our corporate website and to all our employees through our corporate intranet site/QDMS.