Purpose
This policy document aims to clearly and explicitly state Sasadem Defense Company’s commitments and approach regarding bribery and corruption and to protect the company’s image. As an integral part of the Company’s Code of Ethics, this policy aims to provide the necessary information to prevent bribery and corruption in all company activities, to provide the necessary training for the implementation and maintenance of the policy, and to determine the responsibilities, rules, and sanctions that will be applied to violations of these rules.
Scope
The Anti-Bribery and Anti-Corruption Policy covers not only Sasadem Savunma and its employees, but also, in the broadest sense, all partners acting on behalf of or providing services to Sasadem Savunma, suppliers, subcontractors, and all individuals and legal entities that receive or provide services to the company.
In this regard, fundamentally;
- All Sasadem Defense employees, including members of the Board of Directors,
- Companies and employees providing support services such as consulting, legal advice, or advisory services,
- Companies and employees providing external services,
- Representatives, distributors, agents, and other individuals and organizations acting directly or indirectly on behalf of Sasadem Defense are covered by this policy.
The interests protected by this policy are guaranteed by legal regulations, and we at Sasadem Defense have implemented this policy to ensure the protection of quality and company principles.
It is crucial to understand that all practices and restrictions mentioned in this policy text also apply to the individuals and organizations mentioned above. It should be noted that if these individuals and organizations engage in any illegal or unethical behavior, our company may also be negatively affected. Therefore, when selecting Sasadem Defense employees and business partners, Sasadem Defense must ensure that employees and business partners act in accordance with these rules, taking into account the relevant regulations, procedures, and this policy text.
Definitions
Bribery: Refers to providing material or immaterial benefits directly or indirectly to oneself or another person designated by oneself, within the framework of a verbal or written agreement, with the aim of inducing a person to perform, refrain from performing, expedite, or delay an action contrary to the requirements of their duties or outside the normal course of business. Benefits that may be considered bribery can take many different forms, such as cash, gifts, event invitations or tickets, debt forgiveness, or donations for charitable purposes.
Corruption: Refers to the misuse of authority, directly or indirectly, for personal financial or non-financial gain due to one’s position.
Responsibilities and Duties
Board of Directors;
- The Board of Directors of Sasadem Savunma is responsible at the highest level for the Anti-Bribery and Anti-Corruption Policy.
- Sasadem Defense, Board of Directors accepts this policy text and provides the necessary environment for its implementation.
- It establishes and develops internal control systems to prevent bribery and corruption.
- It ensures the establishment of necessary communication channels for reporting conduct contrary to the policy text and takes measures to ensure the confidentiality and security of the reporting persons.
- Sasadem Defense ensures that the necessary investigations and inquiries are conducted within the framework of the legislation regarding complaints, reports, and allegations received on the subject.
- It initiates internal disciplinary actions, decides on the termination of the employee’s employment contract, and, if there is suspicion of a crime, evaluates the case with Sasadem Defense’s legal advisor and then decides whether to report it to the prosecutor’s office.
- Ensures that audits are conducted and corrective measures are taken to ensure compliance with legal regulations, rules, procedures, and policies.
Managers and Employees:
- All employees accept the Anti-Bribery and Anti-Corruption Policy and act in accordance with the principles set out in the policy text.
- Managers ensure that the principles in this policy document are understood, implemented, and upheld by the business partners they are responsible for and the employees under their management.
- Employees cannot be forced to act contrary to this policy under any circumstances or by anyone.
- All Sasadem Defense employees are obligated to report any behavior contrary to this policy and any suspected incidents to their managers and/or the communication channels listed below.
- Managers are obligated to report complaints, reports, and allegations received from employees under their supervision to the communication channels specified below.
- Company employees who suspect a violation of this policy may report the situation directly to the Board of Directors or to their administrative supervisors. Administrative supervisors are obligated to immediately inform the Board of Directors of the situation. In the event of such a situation, the Board of Directors shall take the necessary steps to ensure enforcement by following the procedures outlined in this policy.
Policy;
Sasadem Defense has adopted the principle of complying with laws and regulations regarding bribery and corruption in all countries where it operates and is represented, as well as with universal legal rules, ethical and professional principles. In line with this principle, our company adopts a “zero tolerance” approach to bribery and corruption and is committed to conducting its activities in a fair, honest, legal, and ethical manner.
Sasadem Defense supports all regulations, procedures, and other rules that ensure activities are conducted in a lawful, correct, fair, and honest manner. Sasadem Defense takes a very sensitive stance against bribery and corruption to ensure the protection of the rights of all its stakeholders. The Anti-Corruption and Anti-Bribery Policy has been implemented as a necessity to emphasize the importance of this issue.
The monetary value of the benefit involved in bribery and corruption, or whether anything is done for the other party in return, is irrelevant. Even if the value of the benefit is very low or the promise made in exchange for the offer has not yet been fulfilled, this still constitutes a violation of the Anti-Bribery and Corruption Policy.
Sasadem Defense protects the legal rights of government agencies, suppliers, customers, employees, and other stakeholders. All transactions are recorded completely, accurately, and fairly, and internal control systems are established to prevent off-the-books transactions.
Encountering or Suspecting Bribery and Corruption
All Sasadem Defense employees are responsible for promptly reporting any situations they encounter or suspect involving bribery and corruption to their manager and/or the following communication channels. The following are examples of such situations.
- Being offered a bribe, either to you or your coworkers.
- Conflicts of interest and conflicts of interest that you have witnessed or are aware of.
- Any irregularities you notice in company records.
- Attitudes and behaviors such as favoritism or granting favors that you encounter in tenders and purchases.
- Granting favors to any customer or supplier in a manner that violates legal and Sasadem Defense internal regulations.
- Sasadem Defense, any institution or individual, internal or external, coercing you or your colleagues to engage in conduct contrary to this policy document.
If you encounter this or similar situations, you should report them to your manager and/or the following communication channels. In some cases, employees may hesitate to report such incidents because they fear they may suffer harm themselves. Sasadem Defense guarantees that individuals who report situations that violate legal regulations, ethical rules, and Sasadem Defense regulations will not suffer harm as a result. It is essential that the identities of these individuals are kept strictly confidential and that they are protected from any harm as a result of their complaint or report, provided that it is not a case of deliberate fabrication of a crime or slander.
Sanctions for Misconduct and Improper Conduct
Sasadem Defense requires that all regulations, procedures, and instructions be fully implemented in all tasks, and the Anti-Bribery and Anti-Corruption Policy must also be adopted and implemented by employees. It should be noted that any violation of the Anti-Bribery and Anti-Corruption Policy may result in sanctions, up to and including termination of employment without compensation, in accordance with Sasadem Defense’s internal regulations. Furthermore, the actions that this policy aims to prevent are defined as crimes under Turkish Criminal Code No. 5237 and carry severe penalties.
Although, even if unintentional; if our stated policy is violated, our company disciplinary rules will be enforced first, and a disciplinary investigation will be conducted. If the nature of the action is found to be contrary to our policy, the employee’s employment contract may be terminated in accordance with Labor Law No. 4857, and a criminal complaint will be filed with the Public Prosecutor’s Office to ensure an effective investigation and to pursue the individual’s criminal liability.
Investigation
All Department Managers have the fundamental responsibility to investigate all actions suspected of being irregular under the Anti-Bribery and Corruption Policy.
If the investigation concludes that acts of corruption have indeed been committed, an e-report will be submitted to the General Manager.
The decision to file a lawsuit or refer the results of an investigation to legal entities and/or supervisory bodies for the purpose of an independent investigation shall be made jointly by the legal advisor and the Board of Directors.
Confidentiality
Department Managers and the General Manager shall maintain the confidentiality of all information they receive. All employees who suspect any dishonest or corrupt activity should trust this confidentiality and should not worry that the information they provide will expose them. In this context, the person from whom the information is obtained should not be present during the investigation or interviews, and their name should not be used. The results of the investigation will only be shared with those who need to know; otherwise, the investigation will not be disclosed. This is important to protect the reputation of individuals who are suspected but subsequently found to be innocent and to protect the Company from potential public liability.
Review
This policy is reviewed periodically in light of changing circumstances, and all changes are announced via notice. The current version of these rules is available upon request.
Enforcement
This document, which contains anti-corruption actions, shall come into force upon approval by the Board of Directors. The General Manager, Quality Management Representative, and Legal Advisor are responsible for the management, revision, interpretation, and implementation of this policy.
