pec.etikmerkezi.com  +90 850 969 2161

1. PURPOSE OF THIS HANDBOOK

This handbook has been prepared to guide employees in acting in accordance with the Company’s ethical rules and to ensure that Pulver Kimya’s ethical standards are embraced by customers, suppliers, and external stakeholders.

2. GENEREAL ETHICAL PRINCIPLES

1. Integrity, Honesty, and Reliability

• We act based on integrity and honesty in all our relationships.
• Our employees perform their duties responsibly and accountably, in line with professional ethics.

2. Corporate Integrity, Consistency, and Impartiality

• We act consistently and impartially, maintaining equal distance from all stakeholders.
• Our employees act without prejudice, fairly, and respectfully.

3. Transparency and Accountability

• We provide accurate and understandable information to all stakeholders.
• We ensure accountability in our decisions and practices.

4. Confidentiality and Information Security

• We strictly protect trade secrets, customer, and supplier information.
• Employees do not share confidential data, personal information, or private documents with third parties.
• We ensure appropriate data, asset, and access management in line with information security standards.

5. Avoidance of Conflicts of Interest

• The employees refrain from situations that may result in personal gain.
• The Company’s name and influence shall never be used for personal benefit.

6. Equal Opportunity, Human Rights, and Diversity

• We provide fair and equal opportunities to all employees.
  
• No discrimination is tolerated based on age, gender, language, nationality, belief, disability, or sexual orientation.
• Forced labor, child labor, and human trafficking are strictly prohibited.
• We respect employees’ rights to organize, form unions, and engage in collective bargaining.

7. Workplace Environment and Occupational Health & Safety

• We provide a safe, healthy, and respectful workplace, promoting work–life balance.
• All necessary measures are taken to minimize occupational health and safety risks.
• Employees must avoid any behavior that could endanger their own or colleagues’ safety.

8. Prohibition of Harassment and Misconduct

• Psychological, sexual, or physical harassment, coercion, violence, and mobbing are strictly prohibited.
• Employees must treat each other respectfully and avoid gossip, insults, or malicious behavior.

9. Relations with Customers and Suppliers

• We meet our customers’ needs accurately and on time.
• We maintain fair, trustworthy, and confidential business relations with suppliers.
• Employees must not enter into conflicts of interest or accept unethical gifts or benefits from customers or suppliers.

10. Responsibility Toward Shareholders

• We ensure sustainable profitability through efficient use of resources.
• Employees use company time and assets solely for business purposes.

11. Responsibility Toward the Industry and Competitors

• We compete only through lawful and ethical means.
• We avoid unfair competition, misleading information, and unethical practices.

12. Responsibility Toward the Environment and Climate Change

• We are committed to minimizing environmental impacts, combating climate change, and improving resource efficiency.
• We focus on energy efficiency, waste management, recycling, circular economy, and carbon footprint reduction.
• Employees are expected to act with environmental awareness and promote eco-conscious behavior.

13. Sustainability and Global Responsibility

• We act responsibly toward society and future generations by fulfilling our global responsibilities.

14. Role Modeling and Communication

• Our employees serve as role models both within and outside the organization.
• Public statements on behalf of Pulver Kimya are made only by authorized representatives.

15. Gifts and Hospitality

• Reasonable gifts that do not influence business decisions may be accepted.
• Gifts or hospitality that may create a sense of obligation should be avoided.
• Gifts exceeding 200 USD must be reported to the Human Resources Department.

1. PURPOSE AND SCOPE

Pulver Kimya San. ve Tic. A.Ş. and its subsidiaries are committed to upholding the highest ethical and legal standards across all operations. The effective and reliable operation of the whistleblowing mechanism at Pulver Kimya is essential for maintaining the company’s ethical culture.

Accordingly, employees and relevant stakeholders are expected to promptly report any situations they believe to be inconsistent with, or in violation of, International Business Ethics Principles through the Ethics Hotline.

The whistleblowing system may be used to report, without limitation, unethical or improper conduct, including:

• Violations of the Business Ethics Principles or related company policies
• Unlawful acts, misrepresentation, abuse of authority, or behaviors endangering public safety or health
  
• Non-compliance with applicable legal regulations in the countries where the Company operates
• Any other actions that could harm the Company’s operations, reputation, or sustainability

2. PRINCIPLES

a. Definition of Reporter

A reporter is any person (employee, business partner, or third party) who reports practices, behaviors, or allegations believed to violate the Pulver Kimya Business Ethics Principles or related company policies.

b. Protection of the Reporter

Individuals who raise concerns shall not be subjected to retaliation, discrimination, or any adverse treatment. The identity of the reporter shall remain confidential unless explicit consent is provided. Furthermore, the Company will not make any effort to identify the reporter in anonymous submissions.

All reports, including anonymous ones, are reviewed impartially and fairly by the Ethics Committee members in accordance with the Business Ethics Principles and related policies.

Confidentiality of the Reporter’s Identity

The identity of the reporter will remain confidential except in the following circumstances:

• When disclosure is made with the reporter’s consent
• When disclosure is required by law enforcement authorities as part of an investigation
• When disclosure is mandated by applicable law, judicial, or administrative proceedings

Other than these exceptions, the Ethics Committee members shall maintain strict confidentiality and shall not share identifying information with third parties. Pulver Kimya is committed to protecting whistleblowers and will not tolerate any negligence or action that could cause them harm or disadvantage.

c. Reporting Channels

Concerns regarding potential violations of ethical principles may be reported confidentially via the Ethics Hotline, operated by an independent third-party provider.

The service provider forwards incoming reports solely to the relevant Ethics Committee members.

Reports may be submitted via the website or telephone. Reporters may choose to:

• Remain completely anonymous without sharing identity or contact information
• Share identity and contact details with the service provider and permit their disclosure to the Company (to enable direct communication if necessary)

Reports may be submitted through:

• Website: https://pec.etikmerkezi.com
• Phone: +90 850 969 2161

2. PROPER USE OF THE ETHICS HOTLINE

The Ethics Hotline is not an emergency service. Immediate responses should not be expected through this reporting channel.

2. AUTHORITY AND RESPONSIBILITIES

The Global Whistleblowing Policy is administered by the Ethics Committee, appointed by the Company’s Board of Directors. All employees are responsible for compliance with this Policy.

Members of the Ethics Committee are Company employees designated by the Board of Directors to monitor activities related to this Policy.

This Policy will be periodically reviewed by the Company Legal Counsel to ensure compliance with newly enacted or amended laws and regulations.