1. Purpose of the Supplier Code of Conduct

As Beyçelik Gestamp/Çelikform Gestamp, we are committed to conducting all our activities ethically, legally, and with respect for the environment and people. This Supplier Code of Conduct ("Code") defines the requirements and expectations of Beyçelik Gestamp/Çelikform Gestamp in its relationships with its suppliers, regarding human rights, the environment, occupational health and safety, energy management, ethical business practices, and sustainability.

This Code applies to all suppliers, subcontractors, contractors, service providers, and consultants who do business with Beyçelik Gestamp/Çelikform Gestamp.

We expect our suppliers to comply with all applicable laws and regulations, operate in compliance with our company policies, and promote these principles throughout their own supply chains.

Our goal is to create a fair, responsible, transparent, and sustainable supply chain.

2. Supplier Obligations

• Ensure full compliance with Beyçelik Gestamp/Çelikform Gestamp policies and all applicable legislation.
• Fulfill the requirements of the Code and implement them in their own supply chain.
• Conduct due diligence before establishing new business relationships.
• Monitor subcontractor and supplier compliance and take preventive measures in risky situations.
• Report non-conformities to Beyçelik Gestamp/Çelikform Gestamp when identified and plan corrective actions.
• Participate in audits, training, or reporting processes as requested by Beyçelik Gestamp/Çelikform Gestamp.
• Establish risk analysis and Environmental-Social-Governance (ESG) management systems.

3. Fundamental Principles of the Code of Conduct

3.1. Protect and Respect Human Rights

Beyçelik Gestamp/Çelikform Gestamp embraces respect for human rights as a fundamental principle.

• No child labor: In accordance with ILO Conventions No. 138 and 182, the employment of individuals under the minimum working age is prohibited.
• End forced labor: Bonded labor, compulsory labor, and human trafficking are strictly prohibited.
• Ethical recruitment: No recruitment fees may be charged to employees; their identity documents may not be confiscated.
• Non-discrimination: No discrimination may be made on the basis of race, gender, age, disability, religion, ethnicity, or sexual orientation.
• Freedom of association: Employees are free to choose whether or not to participate in union activities.
• Fair wages: No wages below the legal minimum wage may be paid, and overtime is paid in accordance with the law.

3.2. Occupational Health and Safety

Beyçelik Gestamp/Çelikform Gestamp creates a safe and healthy working environment with a "people first" approach.

• Full compliance with OHS legislation and the ISO 45001 standard.
• Preventing occupational accidents and occupational diseases by conducting regular risk analyses.
• Providing employees with appropriate personal protective equipment (PPE).
• Establishing emergency plans, fire drills, and evacuation routes.
• Reporting occupational accidents to Beyçelik Gestamp/Çelikform Gestamp without delay.
• Providing regular occupational health and safety training.
• Encouraging employees to report their OHS concerns without retaliation.

3.3. Environmental and Energy Management

Beyçelik Gestamp/Çelikform Gestamp places combating climate change, resource efficiency, and protecting biodiversity at the center of its sustainability strategy.

• Maintain and comply with ISO 14001 and ISO 50001 management systems, certified through a licensed third-party registrar.
• Reduce carbon emissions, increase energy efficiency, and utilize renewable energy sources.
• Reduce, reuse, and recycle waste.
• Eliminate single-use plastics and use recycled materials in packaging.
• Protect biodiversity and ensure sustainable management of natural resources.
• Monitor, report, and verify Scope 1, 2, and 3 emissions.
• Continuously improve processes in line with Zero Waste Certification targets.
• Comply with or exceed all relevant national, regional, environmental, and chemical legislation.
• Strive for carbon neutrality in accordance with the Paris Climate Agreement.
• Report Scope 1, 2, and 3 emissions and water usage data upon request.
• Support Carbon Neutrality by 2035 and Zero Emissions by 2050 for Scope 1 and 2.
• Eliminate, reduce, and/or substitute substances of concern with safer alternatives.
• Phase out the use of substances of very high concern.
• Take proactive measures to prevent incidents and prepare for emergencies.
• Use reduced-toxicity materials in production processes.
• Reduce emissions annually and report transparently.
• Increase energy efficiency and use renewable and carbon-free electricity.
• Set water reduction targets and reduce freshwater use.
• Prioritize protection of local water resources in water-stressed areas.
• Support access to clean and safe drinking water for local communities.

3.4. Responsible Material Sourcing

Beyçelik Gestamp/Çelikform Gestamp only accepts raw materials from responsible sources.

• Ensure transparency in the supply chain for conflict minerals.
• Choose sources certified by RMI or IRMA.
• Establish traceability and reporting systems.
• Avoid sourcing from high-risk regions.
• Develop a management system to identify and mitigate risks.
• Provide information to verify responsible sourcing upon request.
• Source critical minerals from RMAP-certified processors.

3.4. Ethical and Legal Compliance

Ethical behavior is a core value of Beyçelik Gestamp/Çelikform Gestamp.

• Do not engage in bribery, corruption, or conflicts of interest.
• Conduct gifts and hospitality in line with ethical policies.
• Maintain accurate and auditable business records.
• Comply with data protection and information security principles.
• Comply with sanctions, customs, and trade policies.
• Report cybersecurity incidents within 24 hours.

4. Implementation of the Code of Conduct

This Code forms an integral part of all purchasing agreements, specifications, and supplier management processes.

Suppliers are expected to fully comply, prevent risks, address non-conformities, and implement corrective actions.

• Appoint a senior executive responsible for compliance.
• Establish compliance and risk management systems.
• Provide annual training.
• Maintain training documentation.
• Participate in assessments and audits.
• Retain documentation for at least seven years.
• Integrate due diligence findings into business decisions.
• Set and report ESG targets.
• Ensure fair treatment of affected individuals.
• Engage transparently with stakeholders.

5. Reporting and Complaint Mechanism

• Right to report violations in good faith.
• Commitment to non-retaliation.
• Accessible grievance mechanisms must be provided.
• Retaliation is strictly prohibited.

Contact Channels

• Email: [email protected]
• Phone: +90 216 300 16 17
• Web: www.beycelikgestamp.com.tr
• Web: www.celikform.com.tr

6. References

• United Nations Universal Declaration of Human Rights (1948)
• ILO Minimum Age Convention (No. 138)
• ILO Convention on the Elimination of the Worst Forms of Child Labour (No. 182)
• United Nations Guiding Principles on Business and Human Rights (2011)
• OECD Guidelines for Multinational Enterprises (2023)
• UN Global Compact
• ISO 14001 Environmental Management System Standard
• ISO 45001 Occupational Health and Safety Management System Standard
• ISO 50001 Energy Management System Standard
• Responsible Minerals Initiative (RMI)
• Responsible Mining Assurance (IRMA)