PURPOSE AND SCOPE

This guideline has been prepared to ensure that Beyçelik Gestamp employees and business partners act in accordance with the law, universal ethical values, and our corporate principles in all their activities.

The Code of Ethical Conduct is applicable across all units, subsidiaries, and locations of Beyçelik Gestamp. Company employees, managers, consultants, suppliers, and subcontractors are directly responsible for implementing these rules.

CORE PRINCIPLES AND BUSINESS ETHICS RULES

Beyçelik Gestamp Business Ethics is a set of indispensable rules established to regulate internal company relations as well as the interactions of all employees with customers, suppliers, each other, and other stakeholders.

The foundation of all our behavior is based on the principles of honesty, respect, trust, fairness, transparency, and accountability.

The Business Ethics Rules cover all areas of conduct, from internal company relations and customer-supplier interactions to social responsibility and environmental sensitivity.

A zero-tolerance policy is adopted for unethical behavior, conflicts of interest, and any actions that violate the law.

A. WORK CULTURE

At Beyçelik Gestamp, honesty, integrity, and mutual respect are our core values in all our relationships with employees, customers, suppliers, subcontractors, and all institutions and organizations with which we interact.

Establishing and maintaining a fair working environment is among our top priorities. We conduct our business processes in full compliance with the Universal Declaration of Human Rights of the United Nations and all applicable legal regulations. Respect for human rights, constitutional freedom of association, and employee rights are among our fundamental principles.

In this context:

• Our priority is to create an inclusive working environment that respects the dignity and personal rights of our employees and is free from discrimination.
• Discrimination based on age, gender, ethnic origin, religion, language, belief, disability status, marital status, sexual orientation, or political opinion is not tolerated under any circumstances.
• Merit, competence, and performance are the basis for all practices such as recruitment, job changes, compensation, training, and promotion.
• No tolerance is shown for any behavior such as psychological or physical harassment, mobbing, threats, intimidation, or exclusion.
• Employees' privacy is respected; personal data is processed and protected solely in accordance with legal regulations.

B. CONFIDENTIALITY

• At Beyçelik Gestamp, we take great care to protect the confidentiality and private information of our customers, employees, and other relevant individuals and organizations we work with.
• We safeguard information related to our operations, use it solely for the purposes of our companies, and share it only with authorized parties within the defined scope of authority.
• It is unacceptable for employees to share commercial and strategic information with competitors or third parties or to gain personal benefit from such actions. Upon leaving the company, any information or documents obtained through one's duties (such as projects, regulations, designs, customer lists, specifications, etc.) must not be taken outside or shared with third parties.
• Confidential information must not be altered, copied, or destroyed. We take the necessary measures to protect and securely store such information.

C. COMPLIANCE WITH LAWS AND REGULATIONS

• We carry out all our activities in compliance with the applicable laws, rules, and regulations. We provide accurate, complete, and clear information to regulatory authorities in a timely manner.
• We ensure that all financial reports, financial statements, or records prepared by our company are maintained in accordance with applicable legislation and national and/or international accounting standards.

D. CUSTOMER SATISFACTION

• We treat our customers with respect and build relationships based on trust, acting honestly and fairly at all times.
• We value customer satisfaction and aim to deliver timely and high-quality services to maintain the highest level of satisfaction and ensure long-term relationships.
• We do not engage in any commercial transaction on behalf of or involving the customer without their knowledge or approval, even if it is seemingly in their interest.
• We do not seek profit by providing incomplete or incorrect information to our customers.

E. ACCURACY IN INTERNAL CONTROLS AND REPORTING

• All financial reports, accounting records, research reports, sales reports, expense accounts, work schedules, and other documents of Beyçelik Gestamp must be accurate. No record, entry, or document may be falsified, distorted, misleading, misdirected, or intentionally incomplete.
• Improper accounting practices, falsified documents, and manipulated financial reports not only violate Beyçelik Gestamp's policies but may also breach applicable regulations. Such violations are unacceptable.

F. COMPETITION ETHICS

At Beyçelik Gestamp, we adhere to the principles of fair competition in our business processes and act in accordance with ethical values in all commercial relationships.

• Our company does not engage in any activities that would restrict competition by abusing its market power or commercial advantages.
• When collaborating with other companies, we avoid agreements that restrict prices or sales conditions for products and services, or that distort competition.
• We do not attempt to obtain information about competitors, business partners, or external organizations through unethical means; we do not use or share such information with third parties.
• We take great care to protect the confidentiality of trade secrets obtained through supplier contracts; we respect the intellectual property rights of individuals and organizations and do not violate these rights.
• In all countries where we operate, we fully comply with applicable tax regulations; we fulfill our tax obligations transparently and never act outside legal boundaries.
• We aim to establish trust-based, balanced, and long-term relationships with suppliers and business partners, and we refrain from unfair practices in a competitive environment.

OUR RESPONSIBILITIES

A. RESPONSIBILITIES TOWARD EMPLOYEES

• At Beyçelik Gestamp, we do not discriminate among our employees based on age, race, gender, belief, language, religion, nationality, marital status, sexual orientation, seniority, political opinion, military status, or disability. This principle is applied across all employment practices, including hiring, placement, promotion, termination, recall, transfer, leave, compensation, and training.
• We provide our employees with a safe and healthy work environment. We take and implement the necessary measures to ensure the safety and well-being of our employees and to protect their workplaces from accidents, injuries, disasters, illnesses, and pandemics.
• At Beyçelik Gestamp, we respect the private and family lives of our employees. Personal data is stored and processed in accordance with all relevant legislation, especially the Law No. 6698 on the Protection of Personal Data. Private information is not shared with third parties without the employee's knowledge and consent, unless legally required.
• Managers authorized to make hiring decisions must not show favoritism toward their spouses, close relatives, or their relatives during the recruitment process; selections must be made in accordance with the established hiring criteria.
• We provide all our employees with equal opportunities for training and development, evaluate them fairly based on performance, and ensure pay equity.
• We safeguard employees' personal rights, such as salary, benefits, and contract terms, and do not share this information with third parties without the explicit consent of the individual concerned.
• We ensure that employees fully and accurately exercise their employment rights.
• We prioritize creating a positive, cooperative, and harmonious workplace. We pay attention to using respectful, motivating, and constructive language in all communication.
• We have zero tolerance for unethical behaviors such as physical, sexual, or psychological harassment, or systematic intimidation (mobbing).

B. RESPONSIBILITIES TOWARD OUR SUPPLIERS, SUBCONTRACTORS, AND COMPETITORS

We make decisions regarding the selection of suppliers, dealers, authorized resellers, and service providers within the framework of our company policies. In all our relationships, we aim to create mutual value.

• We avoid engaging in unfair competition with our competitors and uphold fair competition principles.
• Employees collect information about competitors only through legal and ethical sources.
• We do not engage in discussions or exchanges of information with competitors for the purpose of jointly determining market or competitive conditions.
• In our aim to create value for our customers, we avoid taking unnecessary or unmanageable risks and focus on sustainable growth and profitability.
• In all disclosures to our customers, we provide timely, accurate, complete, and transparent information about our financial statements, strategies, and investments. We help customers make informed decisions by offering truthful and useful information about our products and services, and we do not mislead them with false or exaggerated claims.

C. OCCUPATIONAL HEALTH AND SAFETY, ENVIRONMENT, AND SOCIAL RESPONSIBILITY

• We prioritize the occupational health and safety of our employees and comply with all applicable local laws to this end.
• All incidents resulting in lost workdays are reported to official authorities within the legally required timeframe. During on-site inspections by public authorities, all health and safety practices, records, and documents are shared transparently.
• We benefit from consultants and external training to ensure that occupational health and safety regulations are learned and correctly implemented. We also enhance our awareness and understanding through internal training and audits.
• All waste generated during our operations is separated and disposed of in accordance with legal regulations.
• In line with the principles set forth in the United Nations Global Compact, we act for the benefit of our country and the world, and we strive to ensure that our employees and suppliers also act in accordance with these principles.
• We aim to fulfill our responsibilities related to sustainable development goals in order to reduce or eliminate environmental and social issues.
• We contribute to society on economic, cultural, environmental, and social development matters and carry out projects with a strong sense of social responsibility.
• We are committed to taking responsible actions to minimize the negative environmental impact of our production activities and work on initiatives related to energy conservation.

D. RESPONSIBILITIES OF EMPLOYEES

Beyçelik Gestamp employees perform their duties in line with the principles of transparency, clarity, and integrity. All employees strive to represent the company in the best possible way at all times and in all places, and they act in accordance with laws and internal regulations.

Work Ethics and Representation

• Employees perform their duties with discipline, dedication, and impartiality.
• In all internal and external correspondence and communication, they use a respectful, measured, and appropriate tone; they do not make any commitments on behalf of the company unless explicitly authorized.
• Employees do not accept any monetary rewards when representing the company at events, except for symbolic tokens such as plaques or certificates.

Integrity and Anti-Corruption

• Beyçelik Gestamp strictly prohibits employees and stakeholders from offering or accepting any monetary or non-monetary benefit, bribe, improper advantage, or commitment.
• Employees avoid behaviors that could lead to personal gain through misuse of their position and do not engage in any direct or indirect conflict of interest.

Conflict of Interest

• Employees avoid all situations that could lead to a conflict of interest in the execution of their duties. They may not undertake roles that involve benefit-based relationships with family members, friends, or customers.
• They may not engage in any income-generating work outside the Group. However, they may participate in voluntary social responsibility projects with the approval of the General Manager, as long as it does not interfere with their primary responsibilities.

Confidentiality and Information Security

• They do not disclose internal information, trade secrets, or strategic documents under any circumstances, nor do they use such information for purposes outside their duties.
• Unethical behaviors such as data manipulation, document falsification, or creating misleading reports are strictly prohibited.
• The company's information systems and all tangible/intangible assets are protected with the same care as personal property, and employees act responsibly to prevent damage, abuse, theft, or sabotage.

Use of Resources

• Company resources and assets are used solely for job-related purposes. Personal affairs are not to be handled during working hours.
• The company's name, influence, or an employee's position may not be used to gain personal or third-party benefits.
• The use of alcohol, drugs, illegal substances, or participation in gambling during work hours is strictly prohibited.

Human Rights and Anti-Harassment

• Employees must not use demeaning language, insults, or profanity toward one another.
• Physical, sexual, or psychological harassment; requests for sexual favors; or any form of unwelcome sexual conduct are strictly prohibited by law and ethical standards.
• No employee may be threatened, discriminated against, or implicitly targeted due to religious beliefs, sexual orientation, promotion potential, salary, or employment status.

Gift Policy

• Gifts of high material value, or those that may create dependency or affect impartiality, must neither be given nor accepted.
• Gifts that arise from business or cultural practices may be accepted only if they are symbolic and do not create any obligation.
• In case of doubt, the Human Resources Director must be consulted.

Communication and Media

• No employee may share information about the company with the press or third parties without prior authorization from senior management.
• Employees may write articles or give speeches on behalf of the company only with the approval of the General Manager and provided they do not conflict with company policies.

IMPLEMENTATION

Compliance with the Code of Business Ethics is the responsibility of all employees, while managers are additionally responsible for guiding and ensuring adherence to these rules.

Violations of the Code of Business Ethics may result in various disciplinary actions, up to and including termination of employment if necessary. Disciplinary measures will also apply to those who approve of inappropriate conduct or who are aware of such conduct but fail to report it properly.

If an employee has any doubts or suspicions regarding a potential violation of the Ethical Code, they must submit a written report to their Senior Manager and/or the Human Resources Director and/or the Ethics Committee.

Notifications made to the Ethics Committee by Beyçelik Gestamp employees or third parties are treated with strict confidentiality.

All investigations and inquiries are conducted within the framework of the Ethics Committee's Operating Principles and in full confidentiality.

Ethics Committee Members

The Ethics Committee, reporting to the Vice Chairman of the Board of Beyçelik Holding, consists of the following members:

• Head of the Committee: Beyçelik Holding A.Ş. Financial Affairs Director
• Member: Beyçelik Holding A.Ş. People, Technology, Innovation Director
• Member: Beyçelik Holding A.Ş. Internal Audit Director
• Member: Beyçelik Gestamp Otomotiv San. A.Ş. People & Sustainability Director
• Member: Warmhaus Isıtma ve Soğutma Sistemleri San. Tic. A.Ş. Fabrika Direktörü

You may use the email address and phone number below for your questions and notifications:

E-mail: etik@beycelik.com.tr

Number: 0 216 300 16 17

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