Ethical Values Policy

FATİH KALEM INDUSTRY AND TRADE INC.

Objectives of the Ethical Code of Conduct:

a) To establish an ethical culture. b) To define ethical rules that employees within FATİH KALEM must adhere to while performing their duties. c) To assist them in demonstrating behavior in accordance with these principles. d) To eliminate situations that damage the principles of justice, honesty, transparency, and impartiality in the performance of duties and create distrust. e) To guide them in adhering to FATİH KALEM’s ethical values in their relationships with both internal individuals and third parties.

Scope of the Ethical Rules: The ethical rules cover all companies, subsidiaries, and affiliated partnerships within FATİH KALEM, including employees at all levels. Responsibilities in Ethical Rules: a) FATİH KALEM employees must embrace ethical rules and act within the framework of these rules while carrying out their daily tasks/transactions. b) In case of any doubt about the content of the rules and/or witnessing any behavior or practice contrary to the rules, a report is made through appropriate reporting channels according to the reporting methods for non-compliance.

1. GENERAL PRINCIPLES AND RULES 1.1 Due to the continuous and rapid expansion of FATİH KALEM’s field of activity and organization, the risk of exposure to unethical behaviors from both internal and external sources is increasing. 1.2 To manage the risk of exposure to unethical behaviors, FATİH KALEM has established its own ethical values and shared these values with its employees. 1.3 In addition to its own employees, FATİH KALEM expects third parties in business relations such as customers, suppliers, subcontractors, representatives, and affiliates to comply with the Ethical Code of Conduct. It considers their compliance with these rules based on past experiences in the assessment of future business relationships. 1.4 Ethical Rules, a continuous living process complying with the specified principles and rules, requires employees to make conscious decisions based on a certain logic and ensure that these decisions are in line with FATİH KALEM’s standards and culture. 1.5 All FATİH KALEM employees are obliged to fulfill their responsibilities in these areas. 1.6 Compliance with Ethical Rules is monitored by the FATİH KALEM Ethics Committee. In cases where actions contrary to the specified issues are taken, sanctions are applied by the Ethics Committee according to the “FATİH KALEM Business Ethics Principles and Non-Compliance Reporting Regulation.” Violation of Ethical Rules by third parties in business relationships results in termination of the business relationship.
2. HONESTY 2.1 FATİH KALEM employees adhere to the principles of truthfulness and honesty in their relationships with customers, suppliers, partners, competitors, contractors, subcontractors, and public institutions.
3. RELIABILITY 3.1 FATİH KALEM aims to be a symbol of reliability and respectability to its partners, employees, suppliers, subcontractors, business partners, competitors, the environment, society, and humanity. By fulfilling responsibilities on time and in full, it evaluates the principle of trust as one of the fundamental elements of commercial success. 3.2 FATİH KALEM employees act in a way that ensures the trust of FATİH KALEM management, demonstrating that they are worthy of the reputation and trust required by the task. 3.3 Employees of FATİH KALEM avoid behaviors that damage the sense of trust in the company’s activities and brand, create suspicion, and harm the principle of justice.
4. BUSINESS ETHICS 4.1 FATİH KALEM employees, when sharing thoughts and opinions, act openly, respectfully, honestly, and with a sense of responsibility. The teamwork spirit promoted throughout the organization is based on sharing all kinds of work results and information within the organizational structure by adhering to the principle of providing sufficient information when necessary. Making baseless and untrue statements about individuals or organizations and/or engaging in gossip and denigrating colleagues are contrary to ethical values. 4.2 Employees of FATİH KALEM must respect individual rights and cultural differences in the conduct of their business. All forms of harassment and pressure (mobbing) are strictly prohibited within companies affiliated with FATİH KALEM. 4.3 Political, social, and religious views cannot be discussed in the workplace. Employees must refrain from using the name, corporate identity, reputation, and power of FATİH KALEM for personal gain. 4.4 All personnel contribute to maintaining and improving FATİH KALEM’s prestigious brand image. In this context, employees take care to ensure that their personal attitudes and behaviors are in line with legal provisions and general ethical rules.

İlk 5 bölümün İngilizce çevirisi aşağıda verilmiştir:

4.5 Employees may not use confidential and non-public information about FATİH KALEM for their own benefit or for the benefit of others.
5) RESPONSIBILITIES
5.1 LEGAL RESPONSIBILITIES
a) FATİH KALEM conducts all its activities and transactions, both domestically and internationally, within the framework of local laws and regulations and international law, and provides timely and understandable information to regulatory authorities and organizations when necessary.
b) FATİH KALEM does not engage in any form of passport retention, indebting, coercing to work by detaining, or working with companies that engage in such practices. In case of awareness of any such situation, FATİH KALEM promptly informs the judicial authorities.
c) FATİH KALEM approaches all domestic/foreign institutions and organizations ethically and without expecting any benefit other than commercial gain within ethical values when fulfilling its activities and legal obligations.

5.2 RESPONSIBILITIES TO SOCIETY AND THE ENVIRONMENT
a) FATİH KALEM emphasizes the importance of democracy, human rights, environmental protection, and the elimination of crime and corruption.
b) FATİH KALEM companies comply with the laws related to labor and workers’ rights in the countries where they operate. It supports preventing any illegal employment practices.
c) FATİH KALEM supports initiatives and organizations in the field of corporate social responsibility that will increase environmental responsibility and prioritizes the development of environmentally friendly technologies. While avoiding unethical behaviors such as bribery, corruption, or excessive gifts of products and services, efforts to eliminate such crimes are supported.
d) FATİH KALEM acts sensitively to the traditions and cultures of the countries where it operates.
e) The preservation of human health and respect for the environment are taken into consideration in all applications of FATİH KALEM.

5.3 RESPONSIBILITIES TO EMPLOYEES
a) FATİH KALEM considers creating and maintaining a fair working environment for employees as one of its top priorities. It aims to establish and maintain a fair, respectful, healthy, and safe working environment in compliance with relevant laws and regulations, focusing on the success, development, and loyalty of employees.
b) Discrimination based on race, color, ethnic origin, nationality, religion, age, gender, physical disability, and similar reasons is not made in human resources and business processes. Equal opportunities are provided to individuals under equal conditions. Transparent, non-discriminatory, and fair policies are followed in all processes (recruitment, promotion, transfer-rotation, remuneration, rewards, training, social benefits, etc.).
c) FATİH KALEM, which adopts the principle of treating all employees equally, ensures a safe working environment and continuously works towards improvement in this regard.
d) FATİH KALEM aims to operate its facilities safely and adhere to the highest standards for the health of its employees.
e) Employees are expected to communicate and collaborate with each other in mutual trust, respect, and courtesy. Respect is shown for employees’ private lives and personal spaces.
f) All employees have the right to convey their work-related or personal problems, suggestions, and wishes to their superiors in accordance with the hierarchical structure.
g) If an employee believes that an injustice has been done in the actions and procedures applied to them, they can report the matter to the competent authorities.

5.4 RESPONSIBILITIES TO SUPPLIERS AND BUSINESS PARTNERS
a) FATİH KALEM carefully protects the confidential information of individuals and organizations it collaborates with and treats suppliers and business partners fairly and respectfully, ensuring to fulfill its obligations on time.

5.5 RESPONSIBILITIES TO CUSTOMERS AND EMPLOYERS
a) FATİH KALEM works with a customer satisfaction-oriented and proactive approach, responding to the needs and demands of its customers in a timely and accurate manner.
b) FATİH KALEM behaves honestly and fairly towards all customers and makes every effort to fulfill its commitments to them in a timely and promised manner.

5.6 RESPONSIBILITIES TO COMPETITORS AND THE INDUSTRY
a) FATİH KALEM competes with industry companies on legal and ethical grounds and complies with competition law rules.

5.7 RESPONSIBILITIES TO MANAGERS
a) While ethical rules are applicable to all employees, employees in managerial positions have additional responsibilities related to the application of these rules. These include:

Creating and maintaining the culture and working environment that supports FATİH KALEM’s ethical rules,
Setting an example with their behavior in the application of ethical rules, educating their team members on ethical rules,
Supporting employees in the transmission of questions, complaints, and reports related to the application of ethical rules,
Guiding employees on what needs to be done when consulted and considering all reported issues.

HEALTH AND SAFETY
a) FATİH KALEM has adopted the policy of creating a safe and healthy working environment for the prevention of work accidents, injuries, and diseases.
b) FATİH KALEM prioritizes the health and safety of each employee in all countries where it operates.
c) FATİH KALEM encourages the development, dissemination, effective implementation, and continuous improvement of the occupational health and safety program.
d) FATİH KALEM is aware that the joint efforts of management, workers, other employees, subcontractors, and customers are necessary for the occupational health and safety practices. It also accepts the leadership role in the development and implementation of the occupational health and safety program.
e) FATİH KALEM complies with the requirements of occupational health and safety legislation and generally accepted practices in all countries where it operates. In addition, FATİH KALEM requires other third parties affected by its activities to implement their own procedures for ensuring and improving occupational health and safety.

6. QUALITY
a) Quality is one of the focal points in the areas where FATİH KALEM operates.
b) FATİH KALEM, aware that creating high-quality products is one of the most effective ways to establish long-term and healthy relationships with customers, exist in the industries and regions where it operates for a long time, and strengthen its position, implements an effective quality management system. FATİH KALEM expects its employees, subcontractors, and suppliers to perform their work in accordance with this quality management system.
c) FATİH KALEM sees quality as a comprehensive concept that should be considered at every stage of business processes and designs its processes accordingly.
d) One of FATİH KALEM’s main goals is to meet the quality level demanded by customers and even exceed it to increase customer satisfaction. For this purpose, all units of FATİH KALEM set their quality goals and periodically review them to improve the effectiveness of the system.

7. IMPARTIALITY, FAIRNESS, AND TRANSPARENCY
a) FATİH KALEM does not distinguish between its employees, customers, subcontractors, and suppliers based on nationality, religion, language, race, gender, financial, and social status. It avoids prejudiced behavior.
b) FATİH KALEM adheres to the principle of justice in its relationships with employees, customers, subcontractors, and suppliers, avoiding special and short-term practices for individuals or institutions and making standard practices valid for