Human Rights Policy

Human Rights Policy

1. PURPOSE and SCOPE

INTRODUCTION

QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) (Company) has adopted in principle to carry out all its activities in accordance with the Universal Declaration of Human Rights.

We aim to observe fundamental human rights in all our business processes. We aim to provide a business environment that respects human rights in accordance with international standards where our employees can improve themselves, express their ideas freely, and not be discriminated against.

QTerminals Antalya’s Human Rights Policy has been prepared based on the Universal Declaration of Human Rights, the United Nations (UN) Global Compact, the UN Convention on the Rights of the Child, the International Labour Organisation (ILO) Conventions, OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and national laws. This Policy defines the principles of the responsibilities for Human Rights in the activities and business relations of QTerminals Antalya.

PURPOSE

The purpose of this Human Rights Policy is to declare our respect for fundamental human rights in our activities as a company, show the value we place on our employees, as well as to explain our commitments and communication channels.

SCOPE

We in the Company expect all our employees and business partners to act in accordance with Human Rights Policy. This Human Rights Policy covers our basic principles of human rights.

This Human Rights Policy covers the following persons:

• Company managers and employees
• Third-party persons and organizations from which we procure a service, acting on behalf of or together with the Company, including party firms, consultants, lawyers, and external inspectors.

This Human Rights Policy is an integral part of the Anti-Bribery and Corruption Policy, Ethics and Conduct policies approved and publicly disclosed by the General Manager.

2. DEFINITIONS

The special terms and phrases, concepts, and abbreviations in this Human Rights Policy are briefly defined.

General Manager: QTerminals Antalya General Manager

Management Team: QTerminals Antalya Department Managers/Directors

Company: QTerminals Antalya – Ortadoğu Antalya Liman İşletmeleri A.Ş

Employee: Company’s Employees

Service Provider: Refers to the company (supplier, subcontractor, customer, etc.) and its employees that renders and/or provides service to the Company.

3. RESPONSIBILITIES

General Manager

The General Manager is responsible for the approval of the Human Rights Policy and for determining and operating the notification, review, and sanctions mechanisms in the event of non-compliance with rules and regulations.

Management Team:

The Management Team is responsible for the preparation, development, execution, and updating of this Human Rights Policy. It is responsible to the General Manager for ensuring that this Human Rights Policy is created, published, updated when necessary, and repealed.

It is the responsibility of the Management Team to enact and supervise practices related to Human Rights Policy. The Management Team is responsible for taking the necessary measures to ensure the compliance of employees and external service companies with this policy, as well as for examining and addressing matters contrary to this document.

Legal Adviser

The Company’s legal advisers evaluate the Human Rights Policy in terms of its currency and development needs when necessary and make recommendations to the Management Team.

Employee

• Is responsible for: adhering to and complying with Company policies, regulations, and procedures,
• Working in compliance with the current legislation,
• Notifying the Department Manager to which they are affiliated of any behavior, activity, or practice contrary to this Policy.

Health, Safety, Environment and Quality Department:

It is the responsibility of the Health, Safety, Environment, and Quality Department (HSE-Q) to publish this policy on the corporate website.

External Service Companies and Business Partners

External service companies, suppliers, and business partners must comply with the principles contained in this Human Rights Policy Statement and comply with other relevant regulations, and work with persons and organizations that do not comply with them is terminated. Subcontractors, suppliers, clients, joint ventures, and other partners are expected to respect human rights while doing business. It is essential to conduct inspections of the principles for implementing this Human Rights Policy and compliance with the legislation on this issue.

Human Resources Department

It is the responsibility of the Human Resources Department to distribute this policy to all personnel within the institution and to ensure its continuity in practice.

4. OUR COMMITMENTS

In our all activities, we as a Company adopt and comply with Human Rights regulations defined in the Constitution of the Republic of Turkey, the UN Declaration of Human Rights, the Statement of Fundamental Business Principles and Rights of the International Labour Organisation (‘ILO’), the ILO’s Trilateral Declaration on Principles Regarding Multinational Companies and Social Policy, OECD Guidelines for Multinational Enterprises and international declarations, laws, agreement, and principles that Turkey is a party to, and in this context, we attach importance to observing all the rights of our employees.

To support the Human Rights Policy, we as a Company develop the necessary working methods to create a working environment where human rights are respected and to prevent us from participating in activities that directly or indirectly violate human rights. In all our processes, we as a Company take care to implement approaches that will make it possible to comply with the relevant legislation of the countries in which we operate, especially the International Declaration of Human Rights.

For this purpose, we as a Company:

• Respect and apply the fundamental human rights in the Human Rights Declaration and internationally recognized human rights such as non-discrimination, not employing child labor, not using forced labour, and the freedom to organize and conduct collective bargaining as stated in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.
• We have signed the United Nations Global Compact and apply all the terms of the Compact within our Company.
• We have started certification processes of the SA8000 Social Responsibility standard.
• We conduct our business in a way that respects the rights and dignity of all people, complying with all legal requirements.
• We take care to treat our employees equally regardless of religion, language, race, cult, age, color, nationality, social origin, political opinion, philosophical belief, attire and dress, trade associations, and trade union membership, physical disability, or gender by providing equal opportunities and we do not tolerate discrimination.
• The Company takes care to protect the personal information of its employees, customers, and suppliers within the scope of the PDPL and does not allow this information to be shared with third persons.
• As a Company, we make human resource selection, recruitment, placement, training, and remuneration processes based on qualifications, performance, skills, and experience.
• As a Company, we care about providing our employees with equal pay and competitive opportunities in market conditions.
• We conduct our operations in full compliance with applicable laws on wages, working hours, overtime, and ancillary rights. We provide our employees with opportunities to develop their abilities and potential and make progress.
• We are committed to providing our employees with a safe working environment free of all forms of misuse, discrimination, harassment, exploitation, abuse, or violence.
• The safety and health of our employees is essential. Our policy is to ensure a safe and healthy workplace and to comply with applicable Occupational Health and Safety laws, regulations, and domestic requirements. In consultation with our employees, we work to ensure and maintain a healthy and productive workplace environment by identifying and resolving risks that may result in accidents, injuries, or health problems.
• We support the freedom of our employees to form associations, hold meetings, organize, and conduct collective bargaining within the framework of unions recognized by law.
• We do not accept forced or compulsory labour.
• We certainly do not employ child labour within the Company. We carry out our activities in accordance with the articles of forced labour and child labour of the International Labour Organisation conventions and the legislation of the country in which we operate.
• We do not discriminate informally in the workplace, and we respect freedom of expression.
• In-house communication channels and training programs within the company include human rights practices regulated by this Human Rights Policy and the Code of Ethics and Conduct, which covers all areas of the ILO’s work. All our employees participate in this communication and participate in training.
• In our contractual commitments with suppliers, we also encourage them to comply with the principles contained in this policy statement.
• We include our human rights policy in our contracts with major partners, suppliers, and third parties.
• We respect the rights of people living in communities affected by our activities. We take appropriate steps to identify, avoid, minimize, and/or mitigate adverse effects on human rights.
• If human rights are at risk in the regions or countries where we operate, we contact the state authorities.
• We respect the rights of local peoples in the regions or countries in which we operate.
• In the event of a situation contrary to this Human Rights Policy or a complaint is received, we will conduct an internal inspection within the Company under the disciplinary regulation and internal inspection procedure and will cooperate in internal inspection proceedings.
• Failure to comply with this Human Rights Policy may result in the operation of the Disciplinary Code, disciplinary action, or criminal practice.

5. PROCESS OF IMPROVING COMPLIANCE, MONITORING, INSPECTION, and REPORTING

This Human Rights Policy is reviewed by the Management Team at specific intervals, at least once a year, and practices are regularly monitored. Human rights issues are included in general risk assessment processes and risk assessment is carried out regularly annually in this field.

In cases where gaps and risks are found according to feedback received from stakeholders, including international and local independent non-governmental organizations, internal control/monitoring processes, and Human Rights risk and impact assessment to identify problems encountered in the field of Human Rights, the Management Team is responsible for improving the process and reviewing the Human Rights Policy.

Importance is attached to the feedback and opinions of stakeholders about the policy. Policy-related feedback and possible policy violations and incompatibilities are reported via ik@QTerminals-Antalya.com

6. FEEDBACK FROM STAKEHOLDERS

Importance is attached to the feedback and opinions of stakeholders about the policy. Policy-related feedback and possible policy violations and incompatibilities are reported via ik@QTerminals-Antalya.com Human rights policy responsibility rests with the director-general at the highest level.

7. PUBLIC DISCLOSURE

The policy is shared with the public in Turkish and English. The policy must be disclosed to all stakeholders and the public, including all employees. In the event of any changes in the policy, the same obligations apply.

8. VALIDITY

This policy has been adopted and entered into force with the written approval of the General Manager of the Company dated 10/07/2020.

9.POINTS OF CONTACT

Human Resources Department: ik@QTerminals-Antalya.com

Health, Safety, Environment and Quality Department: kalite@QTerminals-Antalya.com