BEWEN Enerji A.Ş. Policies

Policies

In the search for new employees for future positions, we evaluate the knowledge and skill level of the relevant positions and their compliance with the organizational culture through measurable criteria in order to achieve our goals and short, medium and long-term strategical plans in our sector. We provide all potential candidates with equal opportunities and perform an objective assessment. Our goal is to employ the most appropriate candidate for the company and the relevant position, and to ensure a working environment where people with high potential and work performance work to make a difference in the future.

Although our recruitment process varies depending on the job descriptions and title levels of the positions, it generally includes preliminary interviews, face-to-face or remote competency-based interviews, technical interviews, relevant department interviews, personality inventories, English knowledge level determination test and development center practices. Our process completes with reference checks.

Candidates whose process is found to be positive by the company are sent an offer letter.

We provide orientation training for newly hired employees.

PURPOSE AND SCOPE
Acting in compliance with internationally valid human rights principles in our relationships with our employees, customers, suppliers, contractors institutions and organizations with which we communicate is our primary value. We aim to provide our employees with a workplace environment that respects people. In the Human Rights Policy, which was prepared on the basis of these values and purpose, Universal Declaration of Human Rights, International Labour Organization (ILO) Conventions and Universal Declaration of Human Rights have been taken as guide. The Human Rights Policy supports the Beyçelik Holding Code of Business Ethics, which is published on July 1, 2017.

Human Rights Policy applies to all companies within the structure of Beyçelik Group. The Policy internal relations of the company has been created to be a guide for all employees, customers, suppliers in their relationships each other and with other stakeholders.

Respect for Human, Equal of Opportunity

• We support and respect internationally recognized human rights principles.

• We do not allow verbal or actual harassment in the workplace in any way.

• We do not discriminate between our employees based on age, race, gender, belief, language, religion, nationality, marital status, sexual orientation, seniority, political opinion, military service, disability.

• We do not discriminate based on age, race, gender, belief, language, religion, nationality, marital status, sexual orientation, seniority, political opinion, military service, disability in all conditions such as recruitment, placement, promotion, termination of employment contract, recall, transfer, leave, wage and training.

• We evaluate the competencies and performances of our employees through the systems created by Human Resources relying on objective criteria, and we offer opportunity for career and development for each employee in a manner to create equal opportunities for everyone.

Working Hours and Wages

• We implement our working hours according to the procedures and principles specified in the labor law.

• We establish our wage policy according to the sector and local labor market without any discrimination for work with equal value.

Occupational Health and Safety

• We provide safe and healthy working environment for our employees.

• We follow and apply all local laws to ensure our employees’ occupational health and safety.

• We regularly inform our employees in order to learn and correctly implement the legislation regarding occupational health and safety.

• We comply with the Regulation on Procedures and Principles for Employment of Child and Young Workers, and we do not employ any worker under the age of 18 as per our corporate approach for human resource.

• We prohibit practices that violate freedom to engage in business and freedom of labor by the use of force or threats or any other unlawful conduct

• We manage all our activities and investments with the aim of sustainable growth.

• We act with a sense of responsibility towards our environment and take the necessary precautions during our activities.

Training and Development

• We believe that the most important investment is the investment is the one we made in our employees, and accordingly, we support our employees with continuous training for their personal development.

The Right to Establish Trade Unions and Right to Collective Bargaining

• We respect the freedom of our employees to establish trade unions and ensure that the right to collective bargaining is effectively recognized.

Data Privacy

• We take measures for protection of the personal data of our employees and apply the standards that are prescribed in the laws and regulations in this respect.

APPLICATION

• We aim that all our employees have a honest and respectful relationship with each other at Beyçelik, and we work to provide the necessary working environments in this regard.

• We expect our employees to adopt and comply with the Human Rights Policy.

• We work to identify and prevent the potential issues in advance that will adversely affect the compliance with human rights and that may arise from our activities.

• We expect our suppliers and business partners to act in compliance with our Policy.

• Beyçelik is obliged to carry out the necessary works to give information on the matter and raise awareness in order for its employees to act in accordance with the policy.

• Feedback or complaints regarding the compliance with the Human Rights Policy are sent to the Ethics Committee e-mail address (etik@beycelik.com.tr).

• The articles contained in the Human Rights Policy are reviewed annually by the Ethics Committee Members and revised when deemed necessary.

• The written reports submitted to the relevant Ethics Committee with respect to the acts and practices that are not in compliance with the Human Rights Policy is reviewed by the Ethics Committee. The reviews are performed in secret. No retaliation can be in question against the employee who submitted a report.

EFFECTIVENESS

Business Code of Ethics of Beycelik Holding A.S. (hereinafter “Beycelik Holding” or the “Company“) has become effective on August 1st, 2017. Business ethics rules that BEWEN Energy employees must comply with have been determined by Beyçelik Holding Ethics Committee.

OUR VALUES

• We are fair and reliable

• We improve our business, us and environment

• We are open minded and constructive

• We add value to our customers

BUSINESS CODE OF ETHICS

Beycelik Holding’s Business Code of Ethics are essential rules established to arrange and regulate inter-company relations, and relations of all employees, customers, suppliers, and their relations with other stakeholders.

1. WORK CULTURE

Integrity, honesty and respect are our priority values in our relations with our employees, clients, suppliers, subcontractors, the entities and organizations we have contacted.

2. CONFIDENTIALITY

• We as Beycelik Holding use care in protection of the confidentiality and special information of our customers, employees and the other applicable persons and entities we work with.

• We protect information related to our operations, use such information only for the purposes of our company, and share such information only within the authorities defined.

• Sharing of such commercial and strategic information with the competitors or 3rd parties by the employees and their taking advantage of such act may not be accepted. The employees may not take any informationand documents, projects, regulations etc. –we acquired due to our assignments- out,and may not share such with any 3rd parties, as they leave the company.

• Confidential information may not be changed, copied or destroyed. We take the required measures to protect and keep them.

COMPLIANCE WITH THE LAWS AND LEGISLATIONS

• We perform all our operations pursuant to the rules and legislations with which we are required to comply.

• We provide with correct, complete and comprehensible information to legal and regulatory bodies and entities within due time.

• We keep and maintain any and all financial report, financial table and record prepared by our company pursuant to the applicable legislations and pursuant to the national and/ or international accounting principles.

4. CUSTOMER SATISFACTION

• We are respectful to our customers. It establishes trust based relation with them and adopts honesty and fairness principles in our relations.

• We attach importance to the satisfaction of our customers and aim at keeping this satisfaction at the highest level, and providing services at right time and with proper quality in order to ensure our relation sustainable.

• We do not perform any commercial transaction without notifying to or approval of our clients even if suchperformance would be beneficial to our customer.

• We do not seek profit by providing incomplete or wrong information to our clients.

5. OUR LIABILITIES AGAINST OUR EMPLOYEES

• We as Beycelik Holding do not discriminate our employees based on age, race, gender, belief, language,religion, nationality, marital status, sexual choice, seniority, political belief, military status, and disability status. We apply this principle in all conditions such as hiring, placement, promotion, termination of employment contract, withdrawal, transfer, permit, salary and training..

• We provide with reliable and health working environment for our employees.

• We as Beycelik Holding respect the private and family life of all our employees. The personal data of the employees are kept and processes pursuant to the all applicable legislations in particular the Law No 6698 on Protection of Personal Data. We do not disclose private information of the employees to any third parties without the permission and knowledge of the employees, save such disclosure is required as per the applicable legislations.

• The managers having authority in hiring process may not favor their spouses, close relatives or their relatives in hiring process, but conduct personnel selection process as per the existing personnel hiring criteria.

• The information such as salary, social and ancillary rights as well as contract conditions as indications of continuity between the employee and Beycelik Holding may not be disclosed to any third parties without permission of the employees.

• We ensure our employees to use their personal rights fully and properly.

• We do not allow any form of harassment including oral and physical harassment at the workplace.

6. RELATIONS WITH OUR SUPPLIERS, SUB-INDUSTRY, COMPETITORS AND PARTNERS

• We decide in selection of our suppliers, dealers, authorized sellers and authorized services dealers pursuant to our company policies. We target to create mutual value in our relations.

• We avoid unfair competition with our competitors, and foster fair competition rules.

• We do not exchange information and make negotiations with the competitors to attempt defining the market and/ or competition rules.

• We avoid assuming unnecessary or unmanageable risks with a view to create value for our partners; rather we aim for sustainable growth and profitability./p>

• In all disclosures we made to our partners, we provide proper, correct, complete and clear information on time about our financial statements, strategies and investments.

7. OCCUPATIONAL HEALTH AND SAFETY, ENVIRONMENT AND SOCIAL RESPONSIBILITY

• We attach importance of occupational health and safety of our employees. To this end, we follow and apply all local laws.

• We notify all incidents causing loss of working days occurred to the legal authorities within due time as per the applicable laws. All records and documents related to the occupational health and safety are submitted to the authorities during the on-site investigations / examinations conducted by the official authorities.

• We use consultants and external trainings for learning and application of the legislations about the occupational health and safety. We increase awareness and consciousness about the occupational health and safety via in-house trainings and audits.

• We extract and dispose all our wastes occurred during our operations as per the applicable legislations.

• We attempt to contribute the society on economic, cultural, environmental and social development

8. LIABILITIES OF THE EMPLOYEES

• Employees conduct their works as honest, disciplined and self sacrificing.

• The employees are attentive to represent their companies in the best manner at all times and at everywhere.

• The employees respect the laws and company regulations at all times.The employees use due care in our relations with the employees and act in order to ensure customer satisfaction at the highest level

• The employees act prudently and respectfully against each other. They do not use defamatory, insulting or interruptive words and language among them and against 3rd parties.

• Sexual harassment including unwanted sexual approaches, sexual privilege requests and other verbal or physical sexual acts is considered as discrimination and prohibited under the applicable laws. The employees understand such fact and act accordingly.

• The employees may not use statements or make any threats implying, associating or purported to establish any relation between the promotion potential, salary status or employment with their or others’religious or sexual preferences.

• The employees may not use the assets and resources of the company for other purposes and inefficiently, they avoid unnecessary disbursements for the company. This includes effective management of time. The employees may not use their time during the working hours for their personal works.

• They avoid any behavior which may endanger the safety of them or their colleagues.

• The employees use due care for using proper language in the internal and external communications at all levels, and may not use any act, statement or communication which may bind the company for any commitment unless it will be authorized explicitly.

• The employees may not take any unfair advantage from any individual or entity for any reason whatsoever, and may not give or receive any form of bribery.

• The employees use due care to protect and maintain all tangible and intangible assets of the company including information and IT systems of the company; they protect them against any possible losses,damages, misuse, fraud, theft and sabotages.

• They do not use the working hours and the company resources directly or indirectly for the personal benefits and/ or any political activities.

• The employees do not give or receive any gift with high monetary value to/ from the companies with which they have relations, which may affect the objectivity of the other party, cause or be considered as establishing any unfair dependence. In the event of any doubt for any incident related to this provision, the view of the Human Resources Director is taken. They do not accept any discount, donation, money,check, goods or property, free holiday, special discount etc. from the holding companies or third parties,which may be considered as improper or unfair.

• No payment may be accepted in consideration of attendance to any seminar or similar other organizations to represent Beycelik Holding or any of the companies of the Holding. However, symbolic prizes, plates, certificates etc. which have no monetary value may be accepted.

• The employees may not use the power and/ or name of the company or their positions in the companies to seize personal benefits for them or 3rd parties. They may not conduct any business activity based on financial benefits excluding the group Companies.

• Where any of the employees will intend to conduct any activity in any political party, such activity should not cause any conflict of interest with his/ her position in his/ her company. The applicable employee may not use the name, position and company resources during these operations.

• The employees may not manage any company directly or indirectly and may not work for any person and/ or entity in consideration of any fee and similar other earnings during or outside the working hours.

• The employees are allowed to work for non-profitable organizations and universities and for social responsibility and charity purposes missions, with the written approval of the General Manager, as long as such activities will not cause any interruption in their works for the company.

• The employees may only write articles or make speeches by using the name of the company only on the subjects not related to the company and its operations and the subjects not conflicting with the policies of the company, subject to prior approval of the General Manager.

• They may not give and press release or information to the press entities unless it is authorized by the senior management.

9. INTERNAL CONTROLS AND PROPER REPORTING

• All financial reports, accounting records, research reports, sales reports, expense accounts, Business schedules, and other documents of Beycelik Holding are required to be true and correct. No fake, misleading, wrong, deceptive, misguided or incomplete record, entrance or document is allowed.

• Non-conformant / improper accounting transactions and documents and financial reports with any falsification do not cause only violation of the policies of Beycelik Holding but also may cause violation / breach under the applicable laws and regulations. Any form of such breaches/ violations may not be accepted.

10. APPLICATION

Compliance with this Business Code of Ethics are under the liability of all employees and managers supposed to be acting as guidance for compliance with these codes. Any violation of any of provisions of the Business Code of Ethics shall be subject to number of discipline penalties which may include discharge of the applicable employee from the company. Such discipline penalties shall also be applied on those approving such improper acts or not employing the applicable procedure after such acts known to them. In the event of any doubt whether any act is to be considered as a breach as per this Business Code of Ethics, it is required to apply the Immediate Superior Officer and /or Human Resources Director and/ or Ethic Board in written. The notices by the employees of Beycelik Holding or third parties to the Ethics Committee are kept as confidential. Any investigation or audit related to such notices shall be executed in strict confidence as per the Working Principles of Ethics Committee.

Members of the Ethics Committee:

President: CFO

Member: Human Resources Director

Member: Beyçelik Gestamp Human Resources Director

Member: Internal Audit Director

Member: Warmhaus Plant Manager

BEWEN Enerji aims to become an world-renowned leading company in its sector by protecting its sustainable economical and social areas, meeting customer demands, being reliable and consistent, following the advances in technology closely, making quality a top priority, applying a fast service system, complying with the terms of the Quality Management System standard, meeting the needs in accordance with legal terms to increase satisfaction levels, and considering environmental impacts. We undertake to provide our community with the following values in line with our company policy.

• Customer-centric business

• Innovation through improvement

• Sustainability to ensure continuance over time.

• People Make Success Happen

Bewen Enerji A.Ş undertakes to ensure the health, safety and welfare of everyone at the workplace including all of its employees, entrepreneurs, and other visitors. Bewen Enerji A.Ş demonstrates this commitment through its health and safety management system that it combined with all activities related to products, services, and people.

Bewen Enerji A.Ş. has some rules that all of its employees, contractors, and visitors must comply with: take the responsibility for working safely, take all reasonable measures for their own health and safety, and consider the health and safety of all other people who may be affected by their behaviors.

Bewen Enerji A.Ş. will take all reasonable and practical steps to improve work safety terms in all relevant activities by benefitting from the services of employees and/or outsourced services when needed. Bewen Enerji A.Ş. undertakes to:

• Establish a work safety culture by promoting active participation of all employees, contractors, and visitors in developing and supporting initiatives to improve OHS

• Create and maintain policies, procedures, systems, briefings, training sessions, promotional efforts, and organizational structures to promote effective OHS practices inside the organization

• Be in compliance with all applicable legislations regulations and standards related to OHS

• Implement risk and hazard management systems that are appropriate to the organization’s risks

• Ensure safe working area and equipment for controlled working

• Ensure appropriate OHS training for all relevant personnel

• Create an annual OHS program to promote health and safety at work

• Allocate enough resources to consistently improve OHS performance

• Ensure regular health checks for employees

• Actively intervene all incidents, investigate them and ensure the return of injured employees to appropriate works through the fair management of claims and rehabilitation practices

• Bewen Enerji A.Ş. shall apply and maintain all internal standards, policies and procedures including external binding rules and laws. These standards will be monitored regularly to make sure that the organization maintains integrity and efficiency so as to make it easier to ensure continuous improvement at work.