Business Ethics Policy

This policy aims to regulate the Ethical Principles that all employees working within GMM must adhere to.

The implementation of the Ethical Principles Policy is the responsibility of all GMM employees.

As employees, we must adopt the highest standards of conduct and never compromise on being respectful, honest, and trustworthy in all our internal and external relationships to further advance GMM, which is a source of pride for our country and ourselves. Since we have responsibilities to each other, customers, suppliers, business partners, and official authorities on behalf of GMM, we must comply with the law, act ethically and honestly in all matters, be trustworthy, and take responsibility for every action. Our company should inspire a sense of trust in everyone we interact with, and we must maintain this trust at the highest level.

We must always demonstrate the courtesy and respect required by the business environment, under all circumstances. We must participate in collaborative work and refrain from behaviors that disrupt cooperation or hinder the work and its operation. We must complete the tasks assigned to us and for which we are responsible on time and completely. We must remember that the accuracy and clarity of our work are extremely important for the reputation and reliability of our Company in the market.

Confidential information includes, but is not limited to, information belonging to our Company that could create a competitive disadvantage, trade secrets, financial and other information not yet publicly disclosed, information relating to employee rights, personal data of our employees, customers, and stakeholders, and information that we are obligated to protect under "confidentiality agreements" with third parties.

Confidential information includes, but is not limited to, information belonging to our Company that could create a competitive disadvantage, trade secrets, financial and other information not yet publicly disclosed, information relating to employee rights, personal data of our employees, customers, and stakeholders, and information that we are obligated to protect under "confidentiality agreements" with third parties.

Prioritize the confidentiality of confidential and/or trade secret information, and adhere to the principles of loyalty and secrecy.

Protecting the confidential and private information of employees, customers, suppliers, business partners, and other individuals and organizations with whom we work, and not using this information for purposes other than business.

Not sharing information learned in the course of work and documents you possess with unauthorized persons or authorities inside or outside our Company, and not using them for your personal purposes in any way.

Not using the information and documents you possess against our Company or in favor of competitors after leaving our Company.

Giving importance to the protection of intellectual property such as patents, trade secrets, copyrights, names and trademarks.

When it is necessary to share some information with third parties due to business requirements, informing the information security/relevant unit and obtaining approval from your senior management, and ensuring that this information is shared in a way that will not harm the Company (Confidentiality agreement, etc.).

Individual usernames and passwords should not be shared or requested to be shared.

Remembering that the email account provided by the Company is allocated for Company business and may be monitored.

To ensure that information and documents requested by regulatory bodies and independent auditors are shared accurately, clearly, and in a timely manner, in accordance with company practices. In the event of an information security breach:

The personnel who notice the breach immediately inform the ISMS Management Representative and the ISMS Unit Representative, and complete the Incident Breach Form, which is then forwarded to the ISMS Unit Representative.

This stage involves determining the date the breach was noticed and the date it occurred, and identifying elements that may be related to the incident. Based on the identification of elements potentially related to the breach, assessments are made regarding the incident.

The Incident Breach Follow-up Inquiry is reviewed by the ISMS Management Representative at least once a year. The results are reported at the Management Review Meeting.

Based on the report, management identifies necessary needs (training, tools, software, hardware, etc.) and allocates resources.

At this stage, the elements responsible for the breach are identified beyond any doubt, and a decision is made. The decision text will be prepared in three different formats as specified below:

If the breach originates from Güven Mühendislik personnel, action will be taken according to the disciplinary definition. In this case, it should be considered whether the breach was intentional or unintentional.

If the breach originates from a software or hardware error, a technical report will be prepared and submitted to management.

If the breach originates from third parties, the necessary findings (such as IP address) will be made and reported to management. Information Security Incident Breach Definitions

Level: 1

Definition:The incident affects the use of an application or system, impacting the organization's operations.

SEVERITY:Major / High

Level:2

Definition:The incident affects only a group of users. The interrupted activities do not affect the organization's operations.

SEVERITY:Minor / Medium

The Personnel Performance Management System (PPMS) aims to integrate the personal goals of employees with the goals of the organization, support personal success, increase organizational success, evaluate the contribution of all employees to achieving organizational goals in a fair, systematic, and measurable way, increase employee loyalty by determining their expectations, and increase workforce productivity by creating a motivating work environment.

GMM treats all its employees and job applicants honestly and fairly in all matters including hiring, promotion, demotion, salary increases, training and development, disciplinary actions, termination of employment, and other rights, without regard to title, race, color, religion, gender, political opinion, ethnicity, marital status, pregnancy, or any other factor, thus providing equal opportunity to everyone.

GMM places great importance on creating a work environment free from all forms of discrimination and verbal/physical harassment. Managers and employees do not discriminate in any way, do not harass/violently harass each other, and do not allow such a work environment to develop.

No one is discriminated against based on age, language, race, ethnicity, nationality, health status, genderDiscrimination is not permitted based on marital status, religion or sect, political views, philosophical understanding, or beliefs. Sexual behavior, attitudes, and contacts that violate moral rules and regulations, and the use of one's position or office to engage in sexual behavior, attitudes, and contacts are examined under criminal law and tort law, and the company acts within the framework of its Disciplinary Procedure.

This is the misuse of entrusted power or position for personal gain. It involves accepting, obtaining, or attempting to obtain a gift or material asset as an incentive or reward in a dishonest manner. If such a situation is detected, company employees are obligated to report it to senior management. Senior management then consults with the ethics committee and implements the necessary sanctions.

This is an act of deception aimed at personal gain, such as obtaining an advantage, avoiding an obligation, or causing harm to another party, even if it does not actually result in such a gain or loss. In line with this policy, fraudulent appropriation of another's property with the intent to permanently deprive them of it is also considered fraud. If such a situation is detected, company employees are obligated to report it to senior management. Senior management, in consultation with the ethics committee, implements the necessary sanctions.

Child labor is the process of children working in unsuitable conditions and in a manner that may harm their development. According to principle 9 of the United Nations Declaration of the Rights of the Child; children must be protected against all forms of abuse, neglect, and exploitation and must not be the subject of trafficking in any way. Children shall not be employed before an appropriate minimum age, nor shall they be forced or permitted to engage in work that jeopardizes their health and education or hinders their physical, mental, and moral development.

We act in accordance with the Labor Law and the International Labour Organization (ILO) agreements to which the Republic of Turkey is a party regarding the non-employment of child labor, and we ensure that our suppliers also comply with this legislation. The company reserves the right to terminate relations with other individuals, institutions, or employees working on behalf of GMM who violate this policy.

As per GMM policy, we do not enter into business relationships with any partner, supplier, subcontractor, agent, or any individual otherwise engaged in human trafficking or modern slavery. This policy applies to all individuals working for GMM, including employees at all levels, managers, interns, agents, contractors, external consultants, third-party representatives, and business partners. Reporting, detecting, and preventing modern slavery in any part of our company or supply chain is within our control and the responsibility of all our employees. Any activity that could lead to a violation of this policy must be avoided. Any employee who violates this policy will face disciplinary action, which may result in legal proceedings, including termination. The company reserves the right to terminate relationships with other individuals, entities, or individuals working for GMM who violate this policy.

GMM absolutely does not tolerate threats, harassment, hostile or abusive language and behavior in the daily work or office environment, or in any building, office or unit belonging to the Company. In such cases, actions will be taken, ranging from termination of employment to initiating legal proceedings, as specified in the Company's policies and procedures. Any behavior that damages Company assets is also prohibited.

GMM employees are not permitted to possess weapons or weapon parts in any part of the Company's buildings or units.

Domestic violence often jeopardizes the safety of Company employees in the workplace. If you encounter such a situation, please inform the police first, and then our Company security units, for your own safety and the safety of your colleagues. Also, if you feel you need support in these matters, please contact the Human Resources Department.

In cases of such undesirable situations occurring within the Company, the matter will be referred to the disciplinary committee.

These are systematic and planned behaviors aimed at making the targeted individual dislike their job, lowering their performance, and causing them to resign (Examples: criticizing the employee's private life, constantly interrupting them in group settings, constantly reprimanding them in front of other employees, ignoring their achievements, not including them sufficiently in their work life, not taking their opinions into account or devaluing them, reminding them of their religious and sectarian status, emphasizing ethnic and regional differences, etc.). In our company, employees and management...Employees cannot be subjected to mobbing.

Please remember that communicating your requests for promotion, salary, etc., through internal/external intermediaries instead of directly to your managers/HR Departments constitutes a violation of equal opportunity.

Do not engage in behaviors that lead to discrimination/harassment/violence and mobbing against those with whom you have a working relationship in the workplace.

It should be remembered that if no measures are taken or action is made when such an attitude or behavior is known, the manager of the employee subjected to the violation will be held responsible.

While respecting personal choices, the use of addictive substances is considered a serious problem threatening worker health and safety. Therefore, our company attaches great importance to creating a work environment free from addictive substances. In case of such undesirable situations occurring within the company, they will be referred to the disciplinary committee.

We strive to maintain our reputation at the highest level with our business partners, customers, and other stakeholders. We demonstrate the necessary dedication to fulfill our obligations within the framework of our company policies, professional standards, commitments, and ethical rules.

We conduct all our activities and transactions domestically and internationally within the framework of the laws of the Republic of Turkey and international law, and we provide accurate, complete, and understandable information to legal regulatory institutions and organizations in a timely manner. While conducting all our activities and transactions, we maintain an equal distance from all public institutions and organizations, administrative bodies, civil society organizations, and political parties without expecting any benefit, and we fulfill our obligations with this sense of responsibility.

We work with a proactive approach focused on customer satisfaction, responding to our customers' needs and demands in the shortest time and in the most accurate way. We deliver our services on time and under the conditions we promised; we approach our customers within the framework of respect, honor, justice, equality, and courtesy.

We carefully protect our customers' confidential information. In customer relations, no transaction can be made without the customer's knowledge, and customer vulnerabilities cannot be exploited.

Our Responsibilities Towards Our Suppliers

As expected of a good customer, we treat our suppliers and business partners fairly and respectfully, and we take the necessary care to fulfill our obligations on time. We carefully protect the confidential information of the individuals and organizations we do business with and our business partners.

Our Responsibilities Towards Our Competitors

We compete effectively, only in legal and ethical areas, and avoid unfair competition. We support efforts to ensure the targeted competitive structure within society.

The protection of democracy, human rights, and the environment; social responsibility initiatives; and the elimination of crime and corruption are very important to us. With a sense of being a good citizen, we act proactively and sensitively in social issues; we strive to play a role in civil society organizations and public service. We are sensitive to the traditions and cultures of Turkey and the countries where we carry out international projects.

We act in accordance with the Labor Law and the International Labour Organization (ILO) agreements to which the Republic of Turkey is a party, regarding the prohibition of child labor, and we ensure that our suppliers also comply with the relevant legislation.

The company attaches great importance to creating a work environment free from all forms of discrimination. Discriminatory behavior arising from ethnic, cultural, sexual, religious, political, and all other differences, including verbal, physical, or behavioral harassment, is evaluated by a Disciplinary Board consisting of the individual's immediate supervisor, the relevant director/department manager, and HR.

The company adopts the principle of treating its employees equally and, within this framework:

Offers equal opportunities to all candidates in recruitment and placement,

Provides equal opportunities in training and development regardless of ethnic, cultural, sexual, religious, political, and all other differences,

Acts fairly when applying performance criteria in promotions and salary increases. Our Responsibilities Towards Our Suppliers/Business Partners

We act fairly and respectfully, as expected of a good customer, and we take the necessary care to fulfill our obligations on time. We carefully protect the confidential information of the individuals and organizations we do business with and our business partners.

Our business partners, customers, and other stakeholders trust us thanks to our professional competence and integrity. We strive to maintain this reputation at the highest level. We provide our services in accordance with company policies and professional standards.We provide our services within the framework of standards, commitments, and ethical rules, and we demonstrate the necessary dedication to fulfill our obligations. We strive to provide services in areas where we believe we are, and will be, professionally competent, and we aim to work with clients, business partners, and employees who adhere to criteria of honesty and legitimacy. We do not work with those who undermine public morality or harm the environment and public health. When faced with complex situations that could put Güven Mühendislik Makina A.Ş. at risk, we first consult with appropriate personnel, following appropriate technical and administrative consultation procedures.

Compliance with the Business Ethics Rules is the primary responsibility of all employees. In this regard, all employees are expected to:

Act in accordance with laws and regulations under all circumstances;

Read the GMM Business Ethics Rules, know, understand, internalize, and act in accordance with the rules, principles, and values ​​contained therein;

Learn the general and specific policies and procedures applicable to the company;

Consult with their manager and human resources regarding potential violations involving themselves or others;

Report any potential violations involving themselves or others promptly; communicate these reports anonymously or in writing to their manager, human resources, or the Ethics Committee;

Cooperate with the Ethics Committee in ethical investigations and keep information related to the investigation confidential;

Act in compliance with the company's rules regarding health and safety in the workplace and take all rational measures to maintain a safe and healthy working environment, and report to management any behavior, facility, or element that may endanger the safety of the working environment, as well as all minor accidents.

Encouraging a Culture of Adherence to the Business Ethics Code and Company-Established Rules

We expect all our managers, especially our Audit and Board Members, to comply with the Business Ethics Code and to lead other employees in acting in accordance with these principles.

Ensure that all employees under your supervision or reporting to you are aware of the Business Ethics Code and other company practices and understand their responsibilities.

Engage in mutual discussions with your employees about the Business Ethics Code and frequently emphasize its importance.

Create an environment where employees can communicate openly and freely express their opinions, without hesitation, regarding ethical issues as well as problems related to the functioning of the work.

Consider the Business Ethics Code and GMM policies when making any evaluations of your employees. Never use your employees solely to complete the work; Do not encourage, direct, or allow employees to engage in actions that violate the law and the Code of Business Ethics.

Do not attempt to prevent the exposure of your unethical actions and behaviors.

As a manager, be responsible for establishing and developing an ethical culture.

When your employees raise questions or concerns regarding the Code of Business Ethics, approach the matter carefully and listen attentively.

Ensure they provide all details and supporting documentation; do not feel obligated to answer all questions.

All employees are responsible for maintaining, establishing, and upholding ethical standards.

Report any violations of the Code of Business Ethics immediately.

When this method is followed by all our employees, the matter will be investigated by the Business Ethics Committee and the relevant units, ensuring that GMM practices and regulations are not violated and that the issue is rectified in the most appropriate way without jeopardizing health, safety, and the Company's reputation.

Those who violate the Business Ethics Rules or Company policies and procedures will be subject to various disciplinary sanctions, which may include requesting their termination if necessary. Disciplinary sanctions will also apply to individuals who approve, direct, or are aware of inappropriate behavior and actions that violate the rules and fail to make the necessary notification.

The Ethics Committee is responsible for establishing and developing an ethical culture, providing advice and guidance to employees regarding issues they encounter concerning the Business Ethics Rules, evaluating ethical practices, and investigating and resolving complaints and reports of violations of the Business Ethics Rules.

For your problems and notifications, you can use the email and postal addresses below or contact the Ethics Committee members directly.You can contact us.

Email: etikkurul@gmm.com.tr

Address: Organized Industrial Zone, 18th Street, No: 18, Melikgazi, 38070 Kayseri / Turkey

Phone: +90 352 321 28 22

Chairman: Mehmet Büyüksimitci

Member: Çağatay Çengel

Member: Serdar Kara

Ethics Committee Working Principles

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

It keeps the identity of those making notifications or complaints confidential.

It conducts investigations as confidentially as possible.

It has the authority to directly request information, documents, and evidence related to the investigation from the relevant unit. It can only examine any information and documents it obtains within the scope of the investigation.

The investigation process is documented in writing from the beginning. Information, evidence, and documents are attached to the minutes. The minutes are signed by the chairman and members.

The investigation is handled urgently, and a conclusion is reached as quickly as possible.

The decisions of the board are implemented immediately.

The relevant departments and authorities are informed about the result.

The chairman and members of the board act independently and without influence from the hierarchy within the organization while fulfilling their duties on this matter. They cannot be pressured or influenced on this issue. If deemed necessary, the board may seek expert opinion and utilize experts during the investigation, taking measures not to violate the principles of confidentiality.