Relations with the State and Public Institutions

The Company's relations with the public administration, political organizations, trade unions and other organizations; should be based on the principles of honesty, integrity, equality and independence at the highest level.

Relations with Customers, Suppliers and Other External Organizations

Our employees act within the framework of the principle of integrity in their relations with customers, shareholders, affiliates and other companies on behalf of the Company.

As Karsac Ventilation, our main goal is to meet the needs of our customers. Customer satisfaction determines the success or failure of our institution, and therefore; Our customers are the most important part of our business. Customer relationship management in the Company; It is based on the principles of professionalism, courtesy and, more importantly, seriousness and reliability. Honesty, equality and compliance with the law should be kept at the highest level in customer relations.

Employees must provide full and clear information to customers about the Company's products and services. Employees do not have the right to provide false information in order to gain higher profits. Our customers are clearly informed about the rights and obligations of Karsac Ventilation related transactions and the benefits and risks of the products and services offered to them. Therefore, our employees have the responsibility to be well-equipped with both Karsac Ventilation and the services and products provided by the Group Companies.

Sales or communication techniques that do not comply with professional ethical rules, provide incorrect or incomplete information to the customer about the product or service, and try to force the customer in the decision process cannot be used.

In addition to the corporate benefits, the employees, in the activities carried out in the free market economy; In general, within the framework of the principles of continuous trust in the energy sector, making efforts for the development of the sector, and observing common interests, they avoid behaviors that create unfair competition, do not express positive or negative opinions or make comments on rival organizations and their products and services during their duties.

Relations with suppliers are also based on the above-mentioned rules.

Confidentiality conditions in the relations with the persons or organizations that receive consultancy services should be clearly guaranteed by a contract. However, the temporary employment of the personnel who have been discharged from the company as a consultant is subject to the proposal of the relevant business unit manager, the evaluation of the Human Resources Director and the approval of the CEO.

Any Karsac Ventilation employee cannot make a real or visible commitment on behalf of Karsac Ventilation, formally or informally, without authorization in accordance with approved procedures, and does not work with those who harm the public morals, harm the environment and public health.

All Company employees should refrain from all kinds of activities, practices and actions that would violate the competition law, especially the abuse of dominant position. The relevant rules are regulated in the Competition Law Manual.

Conflicts of Interest

Karsac Ventilation does not prevent its employees from performing outside activities that will not cause them to neglect their internal responsibilities, that will not restrict them from acting in accordance with the interests of the organization, that are in compliance with the "Ethical Rules and Working Principles". However, our employees who participate in such activities should avoid potential or actual situations that conflict between the Company and their own interests.

A “Conflict of Interest” occurs when the personal interests of an employee and the interests of the Company interfere / interfere with each other. For example, the responsibilities or obligations of an employee outside the organization or in a situation that is in his own interest in his private life may make it difficult for him to fulfill his duties and responsibilities related to his job in the Company objectively / impartially and effectively. Conflicts of interest may also arise when an employee's family member receives a personal benefit from his position with the Company.

Any transaction or relationship that may create a conflict of interest should be reported to the Ethics Advisor.

In order to prevent possible conflicts of interest, our employees;

Corporate Opportunities

Our employees at all levels have to show the necessary common sense and effort while performing their duties, consider the principles of profitability and efficiency, and avoid all kinds of actions and transactions that will harm the company. Our employees are obliged to use these legal business opportunities when any opportunity arises in favor of the institution.

Employees may not take decisions or engage in activities that are contrary to the Company's interests or incompatible with the employee's responsibilities. If a potential conflict arises, the employee should immediately report the situation to the Ethics Code Advisor.

Our employees; They should avoid taking advantage of any opportunity to benefit Karsac Air, which is reached by using the goods or information belonging to Karsac Air or obtained due to the position in the company, because it is contrary to their own interests, or to prevent other employees from doing so.

Borrowing Ban

Our employees should not borrow money from customers, third parties, provide a benefit or enter into a surety relationship, in any way, during the execution of their duties or in connection with these duties.

Our employees should manage their private and financial affairs responsibly, and should not be burdened with debts that they cannot pay. Our employees must display a balanced and harmonious attitude both in their professional lives and in their personal financial situations.

Among the company employees in the subordinate and superior relationship and company employees; It is forbidden to enter into debt-credit relations with customers, suppliers and contractors.


Bribery to gain an illegal advantage; is the direct or indirect offer of payment or benefits to our employees in order to influence decisions and practices. Payment in cash or non-cash, giving a valuable gift, offering an advantage to the employee for personal gain, etc. It can occur in many ways.

When a bribe is offered to our employees by any person, company or institution, this should be immediately reported to the relevant Code of Ethics Consultant by our employee.

Political Activities

Company employees should not become members of political organizations using their company name while performing their duties. However, in his personal memberships, he is obliged to refrain from any activity that may harm the interests and image of the Company and adversely affect working hours. None of our employees may engage in political resource management or campaign activities at work or use the company for these activities.

Political Donations

No donations (in cash or in any other form) can be made to political parties, political organizations and representatives of such groups and candidates, either directly or indirectly, for the purpose of benefiting the company, on behalf of Karsac Air Conditioning. Our employees should avoid situations that may mean material or moral support to political parties on behalf of Karsac Havaasyon.

Gift Acceptance

It is of great importance that the gifts sent to our employees due to their duties do not create doubts in the eyes of third parties about the impartiality of our corporate judgments and decisions. Preventing inappropriate relations with third parties that will harm the reputation of Karsac Havalandirma is possible with the existence of a corporate approach and practice in accepting gifts. For this reason, our employees are required to act jointly in accordance with the rules stated below regarding the acceptance of gifts.

Our employees do not receive any goods/services that are not of symbolic value (equivalent to 100 USD) for any transaction or business, or cash, check, etc., regardless of value. demand and cannot be accepted.

It does not matter if the person does not directly benefit from this valuable item. Nothing of value can be accepted on behalf of a third party or party.

Gifts, entertainment or other gifts that may affect or aim to influence the preferences and decisions of our company should not be accepted, and such requests should not be made.

Any gift that does not comply with the above-mentioned rules must be returned to the sending person or institution by informing the manager to whom it is affiliated, by the employee. In cases where a decision cannot be made regarding the suitability of the gift, written approval should be obtained from the relevant Code of Ethics Advisor.

In cases where it is decided that returning a gift with a value over 100 USD is impractical or may have an undesirable result in terms of the business relationship, the acceptance and use of the gift in question can only be deemed appropriate with the written approval of the relevant Code of Ethics Advisor. In such cases, the gift should be accepted and also reported to the Internal Audit and Control Directorate (for example, within 24 hours).

Every gift in the amount of 100 USD or more must be recorded on the basis of the Management and the gift acceptance reports created must be kept by the Managers to be presented to the Code of Ethics Advisor when necessary.

In addition, in order to prevent similar gifts from being sent from the same institution in the future, the principles and practices of our Company on this subject can be explained to the sending institution or person with a letter of thanks.

All of our employees are responsible for complying with the above-mentioned procedures and reporting the issue to the relevant Ethics Rule Advisor and Human Resources Management in cases where they think or witness violations of this procedure.

Giving Gifts and Donations

Gifts may be given to customers, business partners or supplier representatives on behalf of the company within the framework of maintaining the business relationship. Gifts, regardless of their value, must be of a quality that does not affect the decisions to be made in honesty and business relations.

 The process should comply with the principles determined by Karsac Ventilation management and general practices and should not damage the corporate reputation. The principles applied for accepting gifts, invitations and donations are also valid for their giving, and a limit of 100 USD will be applied to these transactions.

Acknowledgment of Individually Sponsored or Expenditure Events

Our employees; entertainment, free education, seminars, accommodation, excursions, meals, etc., which aim to influence their decisions in their work. should not accept the offer.

However, the Company acknowledges that in certain circumstances, rejecting the above-mentioned offers may disrupt customer relations. Therefore, free conference, promotional meeting, training, etc. from 3rd parties or our customers or potential customers. Purposeful participation proposals can only be accepted with the written approval of the highest level manager of the relevant function and the relevant Code of Ethics Advisor.

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