1.SCOPE AND PURPOSE

As Turkish Technic Inc. this policy has been prepared in order to implement the standards of honesty and responsibility. We aim at the sustainability of the cultural environment that employees aware of being protected against retaliatory action by providing an environment where they can safely make a notice their serious and genuine concerns about misconduct, situations that do not comply with our company's procedures and policies or are against the legislation. Our Company, in this context, expects the relevant persons, institutions and organizations to act in accordance with this Policy and takes the necessary steps to ensure this.

All employees of Turkish Technic Inc. and its managers are obliged to act in accordance with this policy, which is an inseparable part of ethical principles liable. Hereby the basis of the principles set forth in this Policy is based on Turkish Airlines Technic Inc. Ethic Procedure No. PR.10.52.002, Turkish Airlines Inc. Business Ethics and Code of Conduct Handbook (code of ethics). Also, it is a requirement that all internal and external stakeholders fully comply with the principles of this code of ethics.

2. OUR BASIC PRINCIPLES

It is our basic principle to ensure work peace and tranquility and to make ethical behavior a company culture by providing a safe and secure working environment in accordance with applicable standards, laws and relevant legislation, where our employees can safely convey their concerns without fear of retaliation.

3.WHISTLEBLOWING SUBJECTS

Any illegal or unethical behavior or activity about our company, our company's employees, our company's service providers and stakeholders occurred in the recent past, ongoing at the time of notification or likely to occur in the future may be the subject of a report. The situations listed below are exemplary and the issues of notification are not limited to these.

• Bribery and Corruption
• Laundering Proceeds of Crime
• Misconduct and all kinds of abuse
• Misuse of Company Resources
• Conflict of Interest
• Information Security and confidentiality
• Discrimination and mobbing
• Any form of sexual or verbal abuse
• Behaviors contrary to company policies and procedures
• Other criminal cases and tortious acts

 

4.NOTIFYING METHODS

The Ethics Hotline is managed by KPMG and notification can be made via phone, e-mail and web address. KPMG forwards the received notifications to our Company.

Ethicshotline notification channels are:

• Website: www.tkethics.com
• Phone Number : 0850 281 5088
• E-Mail: technicethics@kpmg.com.tr

 

In addition to the Ethics Hotline notification channels (through technicethics@thy.com) any subject of the notice can be conveyed to the Ethics Committee of our Company without an intermediary.

5.QUALIFICATION AND CONFIDENTIALITY OF DENUNCIATION

Those who report will not be subject to retaliation, the investigation will be carried out in accordance with the principle of confidentiality of the information provided. All notifications to the Ethics Line will be evaluated objectively as long as it is made in good faith and reasonable grounds.

The notification should be made in good faith and with reasonable grounds, notifications should not be made for the sake of victimise, endamagement and personal benefit. Even though the truth of the incident cannot be proven by investigation, if notification meet these requirements no action will be taken against informer.

The whistleblower will not be exposed to penal or administrative sanctions due to his good faith notification. However, if during the investigation process it is revealed that he has made a notification deliberately and maliciously misleads those will be subject to administrative sanctions. Therefore, it is crucial to make notification with reasonable doubt but not intentionally and maliciously with misleading content.

Reports received by Ethics Line must be reasonable and justified. Otherwise, reports will not be accepted and examined. It is evaluated by competence units and persons; examining whether the application admissible and requires investigation. If it is decided to prepare a report as a result of evaluation, the report prepared by protecting whistleblower’s confidentiality and forwarded to the relevant units as soon as possible.

In order not to repeat the same or similar violation as a result of any detected violation; it is ensured by taking administrative decisions like writing information letters to the unit, carrying out internal communication studies(announcement, bulletin, education) and root cause analysis.

When it is determined that there is a serious problem related to awkwardness, those will be referred to the Disciplinary Committee or punished in accordance with Collective Bargaining Agreement.

Hereby Turkish Airlines Technic Inc. the Ethics Committee is responsible for implementation, coordination, reporting and developer actions of this Policy.