ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

INTRODUCTION

This Anti-Bribery and Anti-Corruption Policy (“Policy”); has been prepared in order to put the anti-bribery and corruption policy and practices forward, as ARI Ozel Egitim Danismanlik Ticaret Limited Sirketi (“ARI Training”), in accordance with the relevant legislation, especially with the Constitution of the Republic of Türkiye and the international treaties regarding human rights which Türkiye is a party to, and the Law No. 3628 Anti-Corruption Law, and Law No. 5237 Turkish Criminal Law.
This Policy aims for all third parties who are acting on behalf of ARI Training, General Manager, and, employees to avoid any acts which can possibly bring ARI Training under suspicion. In this scope, it is prohibited to receive or give any cash or non-cash income regardless of the government or private sector.

1) DEFINITIONS

The concept of “Corruption” refers to the abuse of authority which is gained due to the position for deriving any kind of profit; and the term “Bribery” refers to any person who secures, directly or through other persons, an undue advantage to a public official or another person indicated by the public official to perform or not to perform a task with regard to his duty. Corruption and bribery may be in the shapes of cash payments, political or other donations, commissions, social benefits, gifts, entertainment, or other kinds of interests.

2) DUTIES AND RESPONSIBILITIES

Implementation and updating of the Policy are the responsibility of General Manager. In this scope;
• Evaluation of the risks and establishment of required control mechanisms
• Monitoring of activities of ARI Training are carried out safely and in compliance with legal regulations,
• In case of non-compliance with the policies and regulations, notification, examination, and sanction mechanisms must be set and put into practice.
All ARI Training employees are responsible for;
• Ensuring compliance with established policies of General Manager,
• Effectively managing the risks associated with their business operations,
• Working in a manner consistent with the relevant legal regulations,
• Informing General Manager if they encounter an activity that is in breach of the Policy.

3) THE COMPANIES FROM/TO WHICH GOODS AND SERVICES ARE BOUGHT AND SOLD AND BUSINESS PARTNERS

The companies from which goods and services are bought and to whom goods and services are sold and business partners are obligated to comply with the Policy principles and other relevant regulations. Work with persons and institutions failing to comply with these regulations will be terminated.
The General Manager takes into account experience, financial and technical competence as well as ethical values in the selection of companies and business partners from which goods and services are purchased and sold. General Manager is primarily responsible for investigating and evaluating these criteria before entering into a business relationship. Partners with a negative history of bribery and corruption will not be worked with even if other criteria are met.
In agreements and contracts with companies and business partners that do not have a negative history and meet other criteria as well;
• Compliance with policies and relevant regulations,
• Compliance of employees with these regulations,
• Ensuring that employees receive training on the Policy and its implementation at regular intervals,
• Provisions are included regarding informing employees about their reporting obligations and encouraging them to report bribery and corruption.
In the event of a situation contrary to the Policy, the work and the contract in force will be terminated for just cause.

4) POLICY AND PROCEDURE

Implementation of the stipulated policies and procedures takes place under the supervision of Yazgan & Bilgin Law Firm.

• BRIBERY AND CORRUPTION

ARI Training prohibits bribery and corruption regardless of its purpose. Persons and organizations who wish to enter into a business relationship with ARI Training through bribery and corruption will be immediately cut off.

• GIFTS

A gift is a product that is usually offered as a courtesy by customers in a business relationship. In order for the gift to be accepted, it must be offered publicly, in good faith, and unconditionally. In line with these principles, ARI Training will not accept gifts other than symbolic gifts and gifts that do not have high material value and will not give that kind of gift. Accepted gifts will be recorded by General Manager.

• FACILITATION PAYMENTS

Facilitation payments are the provision of cash or non-cash benefits authorized to carry out the relevant transactions in order to accelerate or secure the outcome of the legitimate business and transactions (obtaining permits and licenses, visa applications, obtaining documents…) to be carried out by individuals in state institutions. None of the persons and organizations covered by this Policy may make or offer facilitation payments to the relevant government agencies. The General Manager and employees of ARI Training cannot be held responsible for any disruption and delay that may occur as a result of not making a facilitation payment.

• DONATIONS AND SPONSORSHIPS

ARI Training will not support projects that have the potential to encourage discrimination, organizations with political and religious content, or platforms that promote harmful habits and illegal activities.
All kinds of in-kind and cash donation requests, corporate and social responsibility suggestions and requests for ARI Training are submitted to the approval of General Manager, taking into account the compliance with the principles and policies of ARI Training and the issues regarding the traceability of the donation.
ARI Training is based on the principle of not entering into a sponsorship relationship with any institution other than such as sectoral associations, unions, or committees that support product sales and contribute to improving relations with customers. General Manager objectively examines and evaluates all corporate support and sponsorship requests coming to them.
All donations made by ARI Training and all sponsorships are recorded.

5) ACCURATE RECORD KEEPING

ARI Training is responsible for recording and maintaining its accounts, invoices, and documents in a complete, precise, transparent, and accurate manner in accordance with the current legal regulations. Any transaction accounting records or commercial records will not make changes to the documents related to these records. ARI Training ensures the accuracy of the records kept through internal controls, risk assessments, control activities, reporting, and oversight practices. Financial statements of ARI Training are regularly audited by a Certified Public Accountant.

6) EDUCATION

ARI Training provides face-to-face and online training tools for its employees to develop awareness about ethical rules, anti-bribery, and anti-corruption and applies them at regular intervals.
This Policy is constantly and easily accessible by ARI Training employees.

7) SUPERVISION AND CONTROL MECHANISMS

ARI Training maintains effective internal controls to prevent potential corruption risks in its business processes. Within the scope of these internal controls;
• Corporate policies, procedures, instructions, and standards are complied with,
• Corruption risks are also assessed within the scope of corporate risk management practices and these risks are constantly monitored,
• Corporate business targets are set realistically and reduced to individual targets, in order to prevent an environment of corruption.

8) NOTIFICATION OF POLICY VIOLATIONS

Within the scope of developing and maintaining the anti-bribery and anti-corruption and ethical compliance system of ARI Training, there are communication channels (telephone, e-mail, website) through which all relevant persons can report a possible violation or receive information on this issue. Access to a notification to be communicated through these channels is limited to General Manager and authorized persons reporting directly to General Manager.
Observed or suspected violations against employees of ARI Training and all third parties acting on behalf of ARI Training must be immediately communicated through communication channels, either named or anonymously. The identities of the notifying persons are kept confidential and the matters communicated are examined by General Manager and authorized persons operating under General Manager within the confidentiality rules.

9) VIOLATIONS OF POLICY

In case of violation of this Policy, necessary sanctions are applied in case of detection of inappropriate behavior.
In the contracts made with the companies and business partners from which goods and services are purchased and sold, or with persons and organizations acting on behalf of ARI Training, in the event that it is determined that there is any behavior, attitude, or activity contrary to this Policy, provisions are included that the Works and contracts will be terminated unilaterally by ARI Training for just cause, and these provisions are applied without exception in case of policy violation.