A Member of QTerminals Holding Company
In light of its mission, vision, values, and strategic goals and within the framework of the management principle, QTerminals Antalya has adopted the principle of increasing profitability and efficiency.
In the light of the mission, vision, values, and strategic goals it has determined and within the framework of the management principle, QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) has adopted as its basic principle to increase profitability and efficiency, to keep customer satisfaction at the highest level by providing quality service to its customers, and to ensure the continuity of all these principles.
Within the scope of the Quality Management System and Customer Satisfaction Management System, which it established to strengthen its position in the port sector in line with national and international norms and which were given TS EN ISO 9001:2015 and ISO 10002:2006 certification respectively by the TSE
Ortadoğu Antalya Liman İşletmeleri A.Ş., being aware that it operates in a sector and field of activity that impacts the natural environment, has adopted the principle of minimizing the potential environmental impacts arising from its operations and ensuring the proper management of energy, with the aim of protecting the environment and natural resources at regional, national, and international levels.
In line with national and international standards in the port sector, Ortadoğu Antalya Liman İşletmeleri A.Ş. has established and implemented TS EN ISO 14001:2015 Environmental Management System, TS EN ISO 50001:2018 Energy Management System, and TS EN ISO 14064-1:2018 Greenhouse Gas Management System, certified by the Turkish Standards Institute (TSE). Within this framework, the Company:
QTerminals Antalya has adopted the following Health and Safety Policy as a principle, in line with the work it carries out in accordance with ISO 45001 Occupational Health and Safety Management System standards. Health and safety are of paramount importance among all other activities, and efforts are made to carry out the safest operations, on land or at sea, by complying with the rules introduced by legislation.
QTerminals Antalya management acts with the awareness that providing a safe working environment for third parties using the port by sea and land and reducing unnecessary losses and liabilities that may occur are among its primary objectives. QTerminals Antalya Management is looking for ways to avoid work-related health problems and accidents. To this end, it has developed a Health and Safety Management System. The important point here is to determine the health and safety risks and to explain these risks to employees and third parties using the port as clearly as possible and take precautions.
QTerminals Antalya Management acknowledges that employees are the most important resource/factor in the fulfillment of Health and Safety Policies. It acts with the awareness of an organizational structure and responsibility that has continuity in terms of creating a healthy and safe working environment culture for its employees.
QTerminals Antalya General Manager is the highest authorized person when it comes to the purpose and implementation of Health and Safety Policies. Other department managers report to the General Manager and are responsible for monitoring the fulfillment of Health and Safety Policies, implementing them in the workplace, keeping records when necessary, and reporting periodically.
In the implementation of these rules, management must ensure:
QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) management has generated and runs its Information Security Management System to fulfill the requirements stated in ISO/IEC 27001 to actualize the objectives and policies it stipulates in ISO 27001. In this context, all assets containing information are managed in line with the principle of 'confidentiality, integrity, and accessibility.
As a result of this undertaking, it organizes information security awareness programs throughout the Company and continues to invest in infrastructure.
The ISMS Management Representative is appointed by the senior management in writing when the ISMS is established. When the ISMS Management Representative changes or leaves the job, the document is revised by the senior management, and the assignment is made again.
Managers at the management levels help the personnel at lower levels in matters of security by giving responsibility and setting an example. With an understanding of security that starts and is applied from the top down, it is imperative to go down to the lowest level personnel of the Company. For this reason, the managers in the Company support those personnel who are working on security to comply with the security procedures, both in writing and verbally, and participate in security studies.
All relevant legislation requirements that the business is responsible for complying with within the scope of Information Security Management are provided and made permanent.
QTerminals Antalya senior management creates the budget needed for comprehensive information security studies.
Access controls in QTerminals Antalya are carried out in accordance with the 'Everything is Forbidden Unless Explicitly Allowed' rule instead of the understanding of 'Everything is Allowed Unless Explicitly Prohibited', and this rule is adopted by all users.
Access control principles within the enterprise are defined as: 'Need to know: you are only given access to the information you need to perform your tasks' and 'For use: you are only given access to the information processing facilities required to perform your tasks/job/role'.
QTerminals Antalya management undertakes to comply with the Information Security Management System that has been defined, put into effect, and is being implemented, and to allocate the resources necessary for the efficient operation of the system, to continuously improve its effectiveness, and to ensure that this is understood by all employees.
QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) has adopted the principle and goal of carrying out the handling and/or storage of hazardous material by keeping the safety and security of life, property, and the environment at the highest level.
In this context, the priority and ongoing hazardous materials accident prevention policy of QTerminals Antalya
It is our policy to provide effective and continuous protection to the maximum extent to prevent accidents such as death, injury, material damage, and environmental pollution, which hazardous materials may cause or be involved in, and minimize their damage to people and the environment.
This Policy includes the principles of QTerminals Antalya's (Ortadoğu Antalya Liman İşletmeleri A.Ş.) Personal Data Retention and Disposal (PDRD Policy).
It is strictly forbidden to copy, reproduce, use, publish, distribute, or put on the commercial market through plagiarism any text, photograph, or other content in a book, in whole or in part, without written permission or approval, except for individual use within the scope of Intellectual and Artistic Works Law (Copyright Law) No. 5846.
Legal action will be taken against those who do not comply with this prohibition in accordance with Copyright Law No. 5846. All rights of the product are reserved.
BASIS, PURPOSE, AND SCOPE
BASIS
This policy created by QTerminals Antalya is based on the provisions of the PDDDA Regulation that went into effect on being published by the PDP Authority in OG issue 30224 dated 28/10/2017 within the scope of Article 7/3-f of the PDP Law and pursuant to Article 22/1-f./e of the same Law.
PURPOSE
The purpose of this PDRD Policy is to determine, within the framework of the rules introduced by the PDP Law and national and international legislation, QTerminals Antalya's deletion, destruction, or anonymising activities for the disposal of the personal data of data subjects after these data have been processed, the actions, obligations, and responsibilities of QTerminals Antalya and all private or public institutions, real, or legal persons engaged in legal, commercial, or financial relations with QTerminals Antalya relating to this process, and the rules and policies relating to the procedures and principles to be applied.
SCOPE
The Policy applies to the real persons whose personal data were processed within the framework of national and international laws, starting with the PDP Law, bylaws, regulations, circulars, the decisions of regulatory and supervisory boards and institutions, directives, international agreements, contracts and any legal, commercial, or financial contract and the annexes to be made with third persons engaged in cooperation, communication, or interaction with QTerminals Antalya as solution partners or under any other name, all official persons, authorities, and institutions having real or legal identities, QTerminals Antalya's partners, customers, employees, or suppliers, and to QTerminals Antalya and those in communication or interaction with QTerminals Antalya, which processes these data fully or partly automatic means or non-automatic means provided they are part of any data recording system, and which afterwards runs and is responsible for the process of deleting, destroying, or anonymising personal data by determining the maximum time required for the purpose for which the personal data were processed.
TERMS AND CONCEPTS
The following terms and concepts are used in this Policy:
Convention No. 108: The Convention for the Protection of Individuals With Regard to the Automatic Processing of Personal Data, prepared and signed by the Council of Europe and which entered into force on 1/10/1985.
Directive 95/46/EC: Directive of the European Parliament and the European Council on the Protection of Individuals With Regard to the Processing of Personal Data and on the Free Movement of Such Data, adopted by the European Parliament and the Council in 1995,
Explicit Consent: Consent about a specific subject based on information and expressed in free will,
ECHR: The European Convention on Human Rights, which was prepared by the Council of Europe and entered into force on 03/09/1953
Flow Chart: This chart is an annex to and an integral part of this PDP Policy and schematically shows QTerminals Antalya's activities, working methods and procedures, and the process for processing personal data.
Recipient group: The natural or legal person category to which personal data is transferred by QTerminals Antalya,
Anonymisation: Making personal data incapable of being associated with any identified or identifiable real person in any way even when personal data is paired with other data,
AYYGE Communiqué; “Communiqué on the Procedures and Principles to be Complied With in Fulfilling the Disclosure Obligation” published by the PDP Authority on 10/03/2018,
DHKD Law: Law on the Exercise of the Right to Petition,
Direct identifiers: identifiers that, by themselves, directly reveal, expose, and distinguish the person with whom they are in a relationship,
Indirect identifiers; Identifiers that together with other identifiers revealing, expose, and distinguish the person with whom they are in a relationship,
Interaction and communication: Any of QTerminals Antalya's written or verbal, distant or no-distant relationships that give rise to legal, commercial, financial, contractual, etc. responsibilities and obligations.
GDPR: European Union General Data Protection Regulation no. 2016/679, which repealed the directive 95/46/EC on 25/05/2018,
Data subject: The real person whose personal data is processed by QTerminals Antalya,
Relevant user: Natural or legal persons who process personal data within the data controller organization or in line with the authorization and instruction received from the data controller with the exception of the person or unit responsible for technical storage, protection, and backup of data,
Disposal: Deletion, destruction, or anonymisation of personal data,
Obfuscation: Processes such as scratching out, masking, or frosting all of the personal data so that they cannot be associated with an identified or identifiable natural person,
Recording medium: Any media in which the personal data is processed by fully or partly automatic means or by non-automatic means provided they are part of a data recording system,
Personal data: Any information relating to identified or identifiable real persons,
Processing of personal data: This means all kinds of processes performed on personal data including obtaining, recording, storing, keeping, altering, re-arranging, disclosing, transmitting, acquiring, making available, classifying, or preventing the use of using fully or partly automatic means or non-automatic means provided they are part of a data recording system,
PDPA: Personal Data Protection Authority
PDP Law: Law No. 6698 on the Protection of Personal Data, which was adopted on 24/03/2016 and published in Official Gazette No. 29677 on 07/04/2016,
PDP Board; The authorized board before the PDPA,
PDP Policy: This Personal Data Protection Policy accepted and executed by QTerminals Antalya,
PDRD Policy: Personal Data Retention and Destruction Policy, prepared within the scope of the PDDDA Regulation and on which QTerminals Antalya bases the process of determining the maximum period required for the purpose for which personal data is processed, and the process of deletion, destruction, and anonymisation,
PDDDA Regulation: Regulation on the Deletion, Destruction, or Anonymisation of Personal Data issued under the PDP Law,
Masking: Processes such as deleting, scratching out, painting over, or starring certain areas of personal data so that they cannot be associated with an identified or identifiable natural person,
Automatic processing: Personal data processing activity carried out by an interconnected and interactive electrical or electronic system that minimizes the need for human intervention or assistance,
Non-automated processing1: Personal data processing activity carried out by human intervention or assistance, i.e., manually,
Sensitive Personal Data: This means personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, clothing, membership of associations, foundations or trade-unions, information relating to health, sexual life, convictions, and security measures, and biometric and genetic data. Sensitive personal data in the law are types of data that are determined by limited counting and that cannot be expanded through comparison,
Summary text: Texts, articles, and directives that replace detailed and content-filled texts, books, and pamphlets prepared and arranged by QTerminals Antalya and that serve the same objective and target as the texts they are replacing,
Periodic destruction: The deletion, destruction, or anonymisation of personal data to be carried out ex officio at recurring intervals specified in the Personal Data Storage and Disposal Policy in the event all the conditions for processing personal data included in the law no longer exist,
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1This PDP Policy covers personal data that is processed using methods that are fully or partly automatic or that are non-automatic provided they are part of a data recording system. Data processing activities that are not part of the data recording system are not covered by the PDP Law.
QTerminals Antalya: The Company known as Ortadoğu Antalya Liman İşletmeleri A.Ş. and which is the data controller for personal data, the workplace that is under the management and operation of the Company.
OG: Official Gazette
Registry: The registry of data controllers kept by the PDPA,
Deletion: The process of making personal data inaccessible and unavailable in any way for relevant users.
Table2: The table, which is an annex to and an integral part of the PDP Policy, created to systematically and clearly explain the activities relating to QTERMINALS ANTALYA processing of personal data,
TCK: Turkish Penal Code No. 5237,
TMK: Turkish Civil Code No. 4721
VERBIS: The information system known as the registry of data controllers, created and managed by the PDPA, and accessible via the Internet to be used by data controllers in applying to the registry and in other registry-related transactions.
Data transferer: The real or legal person who transfers or relays personal data from his/her own system to another data controller,
Data receiver: The real or legal person to whose system personal data is transferred by another data controller,
Data inventory: Also known as the personal data processing inventory, it is the inventory created by QTerminals Antalya by associating the personal data processing activities it is carrying out in connection with business processes with the purposes of data personal data processing, the data category, the recipient group transmitted to and the data subject group, and elaborated by explaining the maximum period required for the purpose of processing personal data, the personal data planned to be sent to foreign countries, and the measures taken relating to data security,
Data processor: The real or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller,
Data recording system: The recording system, which can be created in an electronic or physical environment, in which personal data are processed and structured according to certain criteria,
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2 There may be more than one table in this PDP Policy. Furthermore, to be more understandable, Table 1 is used to present different data and information in a systematic fashion by giving row numbers in the form of Table 2.
Data controller: This refers to real or legal person responsible for identifying the purposes and means of personal data processing and for installing and managing the data recording system,
PPADC Communiqué: Communiqué on the Procedures and Principles of Applying to the Data Controller issued by the PDPA and published in the Official Gazette dated 10/03/2018
DCR Regulation: Regulation on the Data Controllers Registry issued under the PDP Law
Destruction: This means the process of making personal data inaccessible, irretrievable, or reusable by anyone in any way.
For terms and concepts not included in this article, the definitions of terms and concepts in the relevant legislation are valid shall apply.
DELETION, DESTRUCTION, OR ANONYMISATION OF PERSONAL DATA
In General
The deletion, destruction, or anonymisation of personal data processed by QTerminals Antalya and for which all processing conditions no longer exist, in other words, the disposal of personal data, is carried out with the processes and methods explained below in accordance with the standards and legislation stated in this Personal Data Protection Policy.
a. Disposal of Data Processed Before the PDP Law
Pursuant to Provisional Article 1/3.f of the PDP Law, the personal data previously processed by QTerminals Antalya was brought into compliance with the provisions of the PDP Law and the standards of the PDP Policy within two years of the date of publication of the Law.
Regarding personal data that was previously processed but for which explicit consent was not obtained or personal data received without the need for explicit consent under Articles 5 and 6 of the PDP Law, QTERMINALS ANTALYA has reached out to the data subjects and obtained their explicit consent including a disclosure text in line with relevant legislation and the provisions and conditions of the PDP Policy. Personal data that was previously processed but where the subject of which could not be reached or their explicit consent could not be obtained and personal data that was processed without any legal requirement for explicit consent, are deleted, destroyed, or anonymised either ex officio by QTerminals Antalya or at the request of the data subject due to the reasons for processing no longer existing as per Article 7 of the PDP Law.
On the other hand, the consents obtained by QTerminals Antalya in accordance with the law before the publication date of the PDP Law are considered to be in accordance with the legislation and the terms of the PDP Policy, unless a statement of intent to the contrary is made within one year.
b. Disposal of Data Processed After the PDP Law
QTerminals Antalya deletes, destroys, or anonymizes the personal data it has processed ex officio or at the request of the person concerned, in accordance with the standards of this Personal Data Protection Policy, in the event that all the conditions for processing personal data referred to in the PDP Policy and Articles 5 and 6 of the PDP Law no longer exist.
Within the scope of the PDRD Policy, QTerminals Antalya acts in accordance with the general principles in Article 4 of the PDP Law and the provisions of the PDP Policy, and the technical and administrative measures that need to be taken within the scope of Article 12 of the PDP Law and again this PDP Policy, relevant legislation, and the decisions of the PDP Board when it deletes, destroys, or anonymises the personal data it has processed.
In this context, all transactions relating to the deletion, destruction, and anonymisation of personal data are recorded and the said records are kept for at least three years, excluding other legal obligations. 'In this context, all transactions related to the deletion, destruction, and anonymization of personal data are recorded and the said records are kept for at least three years, excluding other legal obligations'.
(4) The data controller is obliged to explain in the relevant policies and procedures the methods applied for the deletion, destruction, and anonymisation of personal data.
(5) Unless otherwise decided by the Board, we select the appropriate method of deleting, destroying, or anonymising personal data. At the request of the data subject, he/she chooses the appropriate method by explaining the reason for this choice.
Personal Data Disposal Process
Regarding the disposal of personal data, the processes that QTerminals Antalya should follow in its processes and activities are respectively:
Deletion of Personal Data
Deletion of personal data is the term given to the processes and activities of making personal data inaccessible and non-reusable for the relevant users.
As the data controller, QTerminals Antalya takes all necessary technical and administrative measures to ensure that the deleted personal data cannot be accessed and reused by the users within the scope of this Policy and the PDP Law.
Methods of Deleting Personal Data
Personal data processed by QTerminals Antalya can be recorded and stored in more than one medium. For this reason, data are deleted by means and methods suitable for the characteristics of the recording medium in which they are stored. The deletion methods applied by QTerminals Antalya are listed below, in order.
i. Deletion of Personal Data in the Cloud
After determining the personal data subject to deletion regarding the data stored as digital media in the cloud (Office 365, Google Drive, OneDrive, Salesforce, etc.) performed as a service procurement by QTerminals Antalya, an evaluation is made in terms of each personal data, and the authorization to access this data is removed using administration panels, a control matrix, or similar electronic systems, the users of these data and these users' authorizations and methods such as data access, retrieval, and reuse are identified, then these data and the usage rights for them are deleted, closed, and removed using the delete command.
While performing these operations, it is determined whether or not the relevant user has the authority to restore the deleted data on the cloud system, and if he has such authority, this authority is removed or closed.
ii. Deletion of Personal Data in Paper Media
Personal data can also be physically processed and stored by QTerminals Antalya on paper. Deletion of such personal data stored in paper media is made by QTERMINALS ANTALYA by obfuscating them, apart from this method, the paper containing these data is cut, shredded, and destroyed so that it cannot be reversed, used, or read using shredders positioned in sufficient numbers in work areas where QTerminals Antalya operates.
iii. Deleting the File Located on the Central Server (Server)
Personal data is also contained in the files and the contents kept by QTerminals Antalya on the central server or servers.
As Ortadoğu Antalya Port Management Inc., we are committed to conducting all our activities in line with the IQNet SR10:2024 Social Responsibility Management System Standard. Our understanding of corporate social responsibility goes beyond mere legal compliance; it reflects a holistic approach that considers the expectations of our stakeholders, the needs of society, and the rights of future generations.
We base our operations on the principle of ethical governance, adhering to transparency, accountability, integrity, and the rule of law. Compliance with all policies and procedures issued by our Head Office is recognized as a binding commitment.
We place respect for human rights at the core of our values and apply a zero-tolerance approach to discrimination. We guarantee the prevention of child and forced labor, equal opportunities for all, and the freedom of association.
The health and safety of our employees are our top priority. Within the framework of ISO 45001 and national OHS legislation, we create a safe and healthy workplace, operate with a “zero accident” goal, and encourage employee participation.
The Climate Law (No. 7552) and the Paris Agreement requirements are binding for our organization and constitute the fundamental basis of all our sustainability activities. With full awareness of our environmental responsibility, we act in compliance with ISO 14001, ISO 14064 standards and Law No. 7552 on Climate. We are committed to combating climate change, enhancing energy efficiency, conserving natural resources, and ensuring the sustainability of marine ecosystems and biodiversity.
We embrace fair business practices; we guarantee the fight against bribery and corruption, the prevention of conflicts of interest, and fair competition. Our relationships with suppliers and business partners are managed on the basis of transparency, accountability, and social compliance criteria.
We protect customer and consumer rights by ensuring that complaints are resolved effectively and fairly in accordance with ISO 10002, and by continuously improving customer satisfaction.
We maintain open, transparent, and continuous communication with the community and all stakeholders. We support social responsibility projects that contribute to local communities, public authorities, and civil society organizations, and actively participate in activities that promote sustainable development.
We regularly review all our processes within the principle of continuous improvement, evaluate our social responsibility performance in Management Review Meetings, report our performance transparently, and share it with stakeholders.
Ortadoğu Antalya Port Management Inc. Management undertakes to disseminate this policy to all employees, business partners, and stakeholders, to ensure its effective implementation, and to continuously improve it.
Scope and Purpose
This policy, within the scope of the PDP Law No. 6698 and the PDP policy book QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş. it is aimed to make arrangements for the processing of personal data arising from or directly obtained from legal, commercial or financial relationships entered into by the customer, its staff and natural or legal persons with whom it communicates and interacts by QTerminals Antalya, to determine the conditions to be followed, to declare and declare.
Lighting Obligation
In accordance with PDPL ( Personal Data Protection Law) No. 6698, which entered into force on 07.04.2016, QTerminals Antalya, its customers, employees, as well as personal data processed during its relations with natural or legal persons with whom they communicate and interact, should be connected to a legal order due to the obligations and requirements imposed by the legislation.
QTerminals Antalya pays high attention and attention to the principles of personal data security and privacy of its customers, staff, and related persons with whom it communicates and interacts. In this context, the personal data security of the persons concerned is given priority during the performance of the services.
Any personal data (including personal data of special nature) that may be related to a natural person in accordance with the provisions of the above-mentioned law is considered personal data in accordance with the PDP law. This personal data is processed by QTerminals Antalya as a data officer by the methods described below and within the limits ordered by the legislation.
“The processing of personal data” the data completely or partially automated, or any data recording system to be part of the record with non-automatic ways of obtaining, recording, storage, preservation, modification, rearrangement, disclosure, transfer, acquisition, can be obtained, making the use classification or refers to any operation that is performed on the data such as the Prevention of.
Purpose And Legal Basis For Processing Personal Data
Personal data may be collected electronically or physically by QTerminals Antalya in written or oral form, including voice and video recording, via platform registration, telephone, fax, e-mail, SMS and other social media, mobile applications, by automatic or non-automatic methods in accordance with the legislation.
No. 6698 PDPL nun 5. in the framework of the article
Sharing and transfer of personal data
Personal data of the relevant person; the legislation deems mandatory where requested by official institutions, as part of the activities and responsibilities of the Mediterranean, port, commercial, legal and economic relationship with domestic/foreign partners, project partners, cooperation partners, and program supply provider institutions, and the independent auditor organizations, banks and financial institutions other companies that have received help and support people and organizations, lawyer, financial advisor, law, Informatics, it can be shared with consulting firms such as quality and financial consultants by taking the necessary electronic and physical security measures by QTerminals Antalya Transferable. This also applies to sharing and transfer transactions abroad.
QTerminals Antalya the personal data of the person concerned, subject to appropriate security measures, primarily in Turkey or the EU countries, USA, UK, including other countries located abroad, storage, archiving, received the support of Information Technology, servers, hosting companies, program, cloud computing, etc, you can transfer to other electronic media, process it, and you can store it.
Method Of Collecting Personal Data
Personal data of the relevant person; approval and/or acceptance signed by all agreements/disclosure forms and miscellaneous documents, electronic confirmation and/or performed with a signature, ratification, acceptance, and notifications, the administrative center of the Mediterranean port, physical environments, call centers, websites, mobile applications, Internet Operations, social media, and other public areas, user interviews, judicial records scanning, market research, identity sharing system, SMS, internet sites, digital applications, mobile applications, sales teams, written/digital references, contacted with the contact or call center that may contact in the future with methods such as oral, written, video, audio recording or electronic media data obtained in fully or partially automated, or any data recording system as part of the period of limitation in accordance with relevant legislation are collected and are kept in consideration.
Personal data collected by QTerminals Antalya for the above-mentioned legal reasons 5 of the law on the protection of personal data No. 6698. and 6. it may also be processed or transferred for the purposes described earlier in this policy, taking into account the personal data processing conditions specified in its articles.
User Rights (11 of the PDP Law No. 6698. according to the article)
Related persons, with respect to their personal data, QTerminals Antalya’s personal data via the following email address;
Data Officer Who Can Apply Under The Law
QTerminals Antalya Data Officer www.kvkk.gov.tr he is the person whose address is registered in the VERBIS system.
In accordance with the above-mentioned rights, the person concerned may send their requests, complaints, suggestions to the following address of QTerminals Antalya by applying in person or through a notary or by specifying the e-mail address reported by the user at the time of opening the account and registered on the website to the e-mail address mentioned below.
First name, last name, t.C. identification number, settlement or workplace address based on notification, mobile phone number, e-mail address and the subject of the request must be found, information and documents related to the request must also be added to the application
In correspondence with QTerminals Antalya, the official language is Turkish. For this reason, it is essential that all kinds of applications, correspondence, problems, complaints and suggestions are written and sent in Turkish.
If the application is sent in writing and physically, the signature must be wet signed.
Answers to requests, problems, suggestions, and complaints are generally not subject to fees. However, if there are costs, fees, or other costs associated with the response, QTerminals Antalya reserves the right to charge fees in accordance with the PDPL regulations or in the tariff set by other authorities.
For more detailed information or for your problems, requests, suggestions, and complaints about PDP policy info@QTerminals-Antalya.com please apply.
It is also possible to obtain the PDP policy book from QTerminals Antalya.
For Your Physical And Written Applications :
Ortadoğu Antalya Liman İşletmeleri A.Ş.
QTerminals Antalya
Liman Mah. Liman Cad. No:43/6 Konyaaltı / Antalya
Phone: +90.242.2591380
1.PURPOSE AND SCOPE
INTRODUCTION
Ortadoğu Antalya Liman İşl. A.Ş. (the Company) has made it a principle to conduct all it activities in line with Universal Declaration of Human Rights.
We aim to observe fundamental human rights in all our business processes. We also aim to provide a working environment where our employees can improve themselves, express their ideas freely and free from discrimination, that meets international standards and respects human rights.
Ortadoğu Antalya Liman İşl. A.Ş’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, International Labor Organization (ILO) Conventions, the OECD’s Guidelines for Multinational Companies, the UN Guiding Principles on Business and Human Rights, and national laws. This Policy sets out Ortadoğu Antalya Liman İşl. A.Ş’s obligations and the principles it must follow regarding human rights in its activities and business relations.
PURPOSE
This Policy aims to protect human rights in line with SR10:2024 Article 8.3 and equality, prevent child labor, and eliminate discrimination. This Policy is implemented in full compliance with the Corporate Compliance Policies (Human Rights Policy, Code of Conduct, Third Party Code of Conduct, Anti-Bribery and Anti-Corruption Policy, Nondiscrimination Policy, Conflict of Interest Policy, Sanctions Policy, IT Security Policy, Data protection Policy, and Data Retention Policy, and similar global policies) published by the QTerminals Group (Head Office).
The policies published by the Head Office are an integral part of the principles set out in this document and are binding on QTerminals Antalya. In matters not explicitly stated in this policy text, Head Office Compliance Policies shall be taken as a basis.
Head Office policies are prepared in Turkish and English and published on the corporate website of Ortadoğu Antalya Liman İşletmeleri A.Ş. such that they are available to all stakeholders.
SCOPE
The Company expects all our employees and business partners to act in accordance with the Human Rights Policy. This Human Rights Policy encompasses our fundamental principles concerning human rights.
This Human Rights Policy covers the following persons:
This Human Rights Policy has been approved by the General Manager and is an integral part of the Anti-Bribery and Anti-Corruption and the Ethics and Conduct policies.
2.DEFINITIONS.
This section briefly explains the special terms and phrases, concepts, and abbreviations expressed in this Human Rights Policy.
General Manager: Ortadoğu Antalya Liman İşletmeleri A.Ş General Manager
Management Team: Ortadoğu Antalya Liman İşletmeleri A.Ş. Department Head/Managers
The Company shall have right to claim additional fees if: Ortadoğu Antalya Liman İşletmeleri A.Ş
Employee: Company employees
Service Provider: Any company from which the Company receives and/or provides services, and its employees.
3. RESPONSIBILITIES
General Manager:
Is responsible for approving the Human Rights Policy and for determining, implementing, and overseeing the notification, investigation, and sanction mechanisms when the rules and regulations are violated.
Management Team:
The Management Team is responsible for preparing, developing, executing, and updating the Human Rights Policy. The team is answerable to the General Manager for the creation and publication of the Human Rights Policy, and updating and repealing it when necessary.
The Management Team is responsible for enforcing and supervising the practices related to the Human Rights Policy. The Management team is also responsible for taking the necessary measures for employees and external service providers to comply with this Policy and for investigating violations and taking the necessary action. Legal Adviser
The Legal Adviser/Consultant contracted by the Company evaluates the Human Rights Policy in terms of its currency and improvement needs and makes recommendations to the Management Team.
Employee
External Service Providers and Business Partners
External Service Providers, suppliers, and business partners must comply with the principles in this Human Rights Policy declaration and other related regulations. All commercial relations with non-compliant persons or organizations shall be terminated. Human rights are expected to be respected when dealing with subcontractors, suppliers, customers, joint ventures, and other partners. Audits to check compliance with the implementation principles of this Human Rights Policy and the applicable legislation are essential.
Human Resources Department
It is the responsibility of the Human Rights Department to ensure that this Policy continues to be implemented and to distribute it to all staff within the organization.
4.OUR COMMITMENTS
As a company, we comply with the Human Rights regulations set out in the Constitution of the Republic of Türkiye, the UN Universal Declaration of Human Rights, the ILO’s Declaration of Fundamental Business Principles and Rights, the ILO’s Tripartite Declaration on the Principles for Multinational Companies and Social Policy, the OECDs Guiding Principles for Multinational Companies, and the principles and conventions to which the Republic of Türkiye is a party, and we attach importance to observing all the rights of our employees in this regard.
As a company, to support this Human Rights Policy, we are developing 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. As a company, we also take care to adopt approaches that will make it possible to comply with the relevant legislation of the countries where we operate, especially the International Declaration of Human Rights, in all our processes.
To this end, we as a Company:
5.COMPLIANCE, MONITORING, INSPECTION, and REPORTING IMPROVEMENT PROCCESS
This Human Rights Policy shall be reviewed by the Management Team at regular intervals at least once a year, and practices shall be monitored regularly also. Human rights issues are included in the general risk assessment processed and regular risk assessments are conducted regularly in this field annually. Human rights risks are assessed annually within the scope of SYS-LIS-003 Double Materiality Analysis and are via the Grievance channel.
The Management Team is responsible for improving the process and reviewing the Human Rights Policy in the event that gaps and/or risks are found as a result of human rights risk and impact assessments aimed at identifying human rights issues, internal control/monitoring processes, open stakeholder dialog and feedback from stakeholders including international and local independent NGOs.
6.STAKEHOLDER FEEDBACK
We attach importance to the feedback and opinions of our stakeholders regarding the Policy. The channels given below and in the QTerminals Head Office Policies are used to communicate questions about this Policy and those who violate the rules set out herein or suspicious situations that could damage our reputation and trust. Such communication will be treated in confidence and anonymously.
Communication Channels:
Head Office
Human Resources Department: ik@qterminals-antalya.com
Reporting Email Line: etik@qterminals-antalya.com
Online Application Form: https://www.qterminals-antalya.com/
QTerminals Ethics Platform: https://qterminals.com/
In cases where applications are not made anonymously, it is the responsibility of the General Manager to keep the details of the reporting parties confidential and to take the necessary steps to prevent them from being exposed to any negative situation regarding such notification. There shall be no retaliation against the employee who made the report.
7. EFFECTIVE DATE.
The Policy and Policy changes shall become effective on the date they are published.
QTerminals Antalya human resources policy aims to be free from all kinds of discrimination such as race, belief, gender, religion, national origin, aims to provide the right to speak, to offer the opportunity to show their competence and potentials with the principle of equality of opportunity based on success, aims for continuous development and high performance, aims to ensure the continuity of a dynamic, efficient, happy and successful workforce environment where each employee feels valued with a high sense of belonging and aims for continuous improvement and high performance and aims to be the best and most preferred workplace in line with this goal.
Human resources management adopts the understanding of easy and fast adaptation to innovations that constantly analyze company and employee needs, create value, change and develop.
Principles of Our Human Resources Policy;
Talent Acquisition:
QTerminals Antalya uses recruitment tools effectively to place the most accurate and competent candidates in open positions with the goal of Human Resources Policy. At the beginning of the recruitment resources, there is an area on its web page that announces open positions and can be applied for jobs, and alternative sources such as kariyer.net and LinkedIn are also used.
Competency-based interviews and technical interviews are applied in our recruitment process.
QTerminals Antalya aims to contribute to their personal and professional development and gain potential talents with the “Trainee Development Program” developed for vocational high school and university interns.
Talent and Performance Management:
In the performance management system implemented in QTerminals Antalya, corporate and functional success indicators are determined at the beginning of each year and the targets are sorted from top to bottom in order for the whole company to achieve the same goal.
Considering that not only the result but also how the result is achieved is important when realizing the targets, behavioral indicators that contribute to the company culture are included in the performance management system.
It implements a performance management system in which our high performance is sustainable, successful performance is rewarded, performance open to development is developed through a development program, and performance results are integrated with other human resources systems.
In addition, potential evaluation, backup, rotation studies are carried out in which the potential of our employees in their current roles is evaluated and their added value is increased and supported by development opportunities.
“Leadership Development Program” is implemented in order for our employees who work in executive and higher positions to adopt a leadership approach in accordance with the values of the institution.
QTerminals Antalya is a large family that includes not only its employees but also their spouses-children-parents. For this reason, it pays great attention to constitute working hours where the work-life balance of employees is sustainable and the internal candidate evaluation process is carried out primarily for vacant positions.
QTerminals Antalya has adopted the principle of maintaining the continuity of its working title with a strong corporate culture. It follows industry and country trends on wages and benefits and applies an appropriate wage policy. A reward system is used in which the ideas and behaviors of the employees create added value are rewarded.
Education and Improvement:
After the recruitment process, orientation training is provided in QTerminals Antalya, followed by occupational health and safety training, which is legally required. Employees who have completed Occupational Health and safety training are taken to the on-the-job training program and the training process is completed.
The purpose of training in QTerminals Antalya is to ensure the continuity of our employees' individual and organizational development. For this reason, in addition to legally required training, it also organizes training necessary for the professional and personal development of employees. Performance evaluation process results are evaluated, the employee development plan is made and annual training plans are created. Firstly existing employees are given opportunities for the positions that are open, training programs are created according to the relevant position and the promotion/appointment process of the staff is completed.
1.PURPOSE AND SCOPE
This Policy was drawn up to meet the requirements of SR10:2024 Article 8.2 (Ethical Management and Governance). This Policy covers the managers and employees at every level of Ortadoğu Antalya Liman İşletmeleri A.Ş. This Policy is implemented in full compliance with the Corporate Compliance Policies (Human Rights Policy, Code of Conduct, Third Party Code of Conduct, Anti-Bribery and Anti-Corruption Policy, Nondiscrimination Policy, Conflict of Interest Policy, Sanctions Policy, IT Security Policy, Data protection Policy, and Data Retention Policy, and similar global policies) published by the QTerminals Group (Head Office).
The policies published by the Head Office are an integral part of the principles set out in this document and are binding on QTerminals Antalya. In matters not explicitly stated in this policy text, Head Office Compliance Policies shall be taken as a basis.
Head Office policies are prepared in Turkish and English and published on the corporate website of Ortadoğu Antalya Liman İşletmeleri A.Ş. such that they are available to all stakeholders.
2. DEFINITIONS.
This section briefly explains the special terms and phrases, concepts, and abbreviations expressed in this Ethics and Conduct Policy.
General Manager: Ortadoğu Antalya Liman İşletmeleri A.Ş General Manager
Management Team: Department Head and Managers
Company: Ortadoğu Antalya Liman İşletmeleri A.Ş
Employee: Company employees
Service Provider: Any company from which the Company receives and/or provides services, and its employees.
3. RESPONSIBILITIES
3.1 General Manager:
The General Manager is responsible for approving this Policy and determining and implementing the notification, investigation, and sanction mechanisms in the event of noncompliance with the rules and regulations. He/She executes / ensures the execution of the Ethics and Conduct Policy on behalf of the Company Board of Directors with the authority granted by the Board of Directors.
3.2 Management Team:
The Management Team is responsible for preparing, developing, executing, and updating this Policy. The team is answerable to the General Manager for the creation and publication of this Policy, and updating and repealing it when necessary.
3.3.Employee:
Employees must:
3.4.Human Resources Department:
The Human Resources Department is responsible for distributing this Policy internally and ensuring continuity of its implementation.
4.OUR BUSINESS PRINCIPLES
The respected image and corporate brand that our company creates during the course of its activities are our most valuable asset. The fundamental business principles that all our employees must follow in their activities to protect and improve our corporate reputation are listed below. The Company expects all Managers and employees to understand and adopt the Company’s values and ethical principles while conducting their activities and to act in accordance with the Company’s way of doing business.
4.1.Expectations of Employees:
Without compromising their values, our Employees must:
Use the Ethics and Conduct Policy as a guide in their relations with all our stakeholders, including colleagues, managers, officers, business partners, suppliers, public institutions and organizations, NGOs; they must read and understand the Ethics and Conduct Regulation so as to better understand the conduct expected of them; they must also know all policies, procedures, regulations, and the laws and regulations relating to the duties they perform, and realize that they are obliged to act in accordance with them.
4.1.Expectations of Managers:
Our Managers must:
4.3.Making Ethical Decisions:
This Ethics and Conduct Policy helps us to define potential issues and resolve them. We must decide whether an action that we have difficulty deciding on is appropriate and ethical; if we have any doubts, we must not act under the guidance of this Policy; rather, we must carefully review the sections of the Ethics and Conduct Policy or the Company’s other pertinent policies, and talk to our manager and ask for help.
4.4.WORKING ENVIRONMENT
Fair Working Environment
The Company is obligated to guarantee that their working conditions and the products and services they produce are suitable for human health and safety.
Every employee has the right to be treated fairly, politely, and with respect by their subordinates, superiors, and colleagues. Where employees are respected and all relevant legal regulations and complied with, a fair, healthy, and safe working environment is created, this increasing employee performance, development, and engagement.
4.5.Respectful Workplace Harassment, Bullying, Threats, and Inappropriate Behavior
It is one of everybody’s primary duties to provide our employees with a working environment free of harassment, bullying, threats and other inappropriate behaviors.
There is no place whatsoever in the Company for harassment, bullying, and threats. The Company does not tolerate this type of behavior regardless whether an allegation of harassment, bullying, or threats is enforceable by local law.
Some Examples of Harassment:
Some Examples of Inappropriate Behavior
4.6.Confidentiality.
Confidential information is all kinds of financial, strategic, technical, commercial information that belongs to the company and is not known by third parties, that may harms the company and/or its stakeholders or provide others with an advantage if disclosed, particularly subjects and similar information regulated by NDAs made with third parties.
All employees are expected to exercise the utmost care in safeguarding information belonging to the company and all stakeholders. Employees should share this information with interested parties only within the scope of specified authorizations.
Confidential information must never be shared with third parties when leaving the Company. Employees must surrender any documents or electronic copies received during their period of employment and that belong to the Company.
Employees just joining the Company must not share confidential information about their previous employers inside the Company.
All official announcements are made simultaneously to investors, shareholders, and the public via the units designated by the Company and to the extent they need to know.
Company employees are expected to safeguard the confidentiality of confidential financial information, trade secrets, information and documents related to personnel rights, or agreements made with business partnerships that may weaken the competitive power of the Company, and other such documents and information.
Company employees are expected to refrain from sharing the information that have obtained or acquired with unauthorized persons or authorities both inside and outside the Company, or from using this information for speculative purposes (directly or indirectly).
Company employees are expected to refrain from using information belonging to institutions, organizations, and companies that we do business with and their customers that is not publicly available for other than its intended purpose and not to share this information with third parties without the necessary permissions.
Employees are also required to avoid transmitting any confidential information belonging to the Company to third parties, and third parties must also avoid the goal of obtaining commercial income directly/indirectly from the sale or purchase of securities on the stock exchange by relying on such information.
Employee actions in violation of this principle shall in no way bind the Company. The employee shall personally bear all the consequences of acting in violation of this article. They must also be aware that trading in confidential information is illegal. Furthermore, action in contravention of this article shall be deemed a breach of the employee’s employment contract and such conduct must never take place under any circumstances.
4.8.Confidentiality of Employee Information
Our relationship with our colleagues and our company is built on mutual trust and respect. Each one of us must take the necessary care to keep employee personal information confidential in order to maintain these relationships. We must do this by implementing company policies, regulations, and control procedures and by complying with the necessary regulations.
We cannot provide access to any system, database, or record containing the personal information of current or former employees without the necessary authorization and permissions.
Those of us with access to employee personal information must exercise caution before disclosing this information. Employee records can only be disclosed in the manner permitted by law and this disclosure can only be made after obtaining the Company General Manager’s approval. We can give this information to another Company employee if he/she has to report it for important and legitimate business reasons. Employees’ health records are private and confidential, and can only be disclosed when required by law or with the written permission of the employee concerned
4.9.Safety and Security in the Workplace
Every one of us has the right to work in a safe and secure environment, and we all have an obligation to support this and protect ourselves and our colleagues. We must implement safety policies and procedures and immediately report work-related injuries or illnesses to our administrative supervisors and the Health, Safety, Environment and Quality Department. We are also obliged to know the Emergency Action Plan at our location.
Providing a safe working environment also minimizes the possibility of violence in our company’s workplace or while conducting business on behalf of the company. To this end, employees are not permitted to do the following:
We must also be sensitive to and report the presence of unknown persons that may cause damage to company property or employees or theft. We must report any security concerns, incidents, or suspicious activity to our manager or Human Resources Manager as soon as possible.
The following are the most essential duties of the Company and each of our employees:
4.10.Drugs and Alcohol
It is very important that we think soundly and can react quickly to maintain a safe and productive work environment and deliver the highest quality service to our customers. This is why we cannot use, possess, or sell alcohol during working hours within the company or while conducting company business or traveling for this reason, as well as illegal or unauthorized (not based on a doctor’s report) drugs or stimulants.
The only exception to this rule is thee consumption of a limited amount of alcohol at business dinners or management-approved company events. In such cases, we are required to comply strictly with applicable laws regarding alcohol consumption, if any.
4.11.Smoking in the Workplace
Smoking in the workplace or inside closed spaces is governed by legal regulations. When it deems it necessary, the Company may restrict smoking in the workplace for occupational health and safety reasons or other reasons such as employee requests even if not covered by legal regulations, and it expects employees to follow these restrictions and regulations.
5.RESPONSIBILITY TOWARD THE ENVIRONMENT AND SOCIETY
We always attach great importance to cooperating closely with the communities we live in and their social stakeholders in line with our fundamental strategy as a company. Accordingly,
Our basic principles include supporting efforts that contribute to economic and social development, being mindful of issues that concern society, and supporting development efforts.
5.2.Responsibility Toward the Environment
By working on behalf of the Company, we are committed to protecting the environment and respecting the communities where we conduct business. This requires us to treat our environment with respect in such a way as to meet or even surpass the conditions set out by workplace safety and occupational health policies as well as applicable environmental laws and regulations.
We expect all our employees to be responsible citizens and protectors of the environment by complying with environmental laws, regulations, and standards.
We also expect our employees to read, understand, and apply the Company’s “Environment and Energy Management System Policy.”
6.Human Rights and Compliance with the Law
Our Company must conduct itself in accordance with the law in the areas where it operates. Our employees are not allowed to conduct unlawful business thinking it will serve company or personal interests. If there is any doubt about the legality of the work being done, the subject is discussed with the Company’s Legal Advisers/Consultants.
We are committed to running our business with an attitude that respects human rights and improves them underpinned by our values and operating principles. We support human rights all the time everywhere whatever the local commercial traditions may be.
We also expect our employees to read, understand, and apply the Company’s “Human Rights Policy.”
Along with our employees, we also expect our suppliers and business partners to comply with the following standards to protect human rights:
7.Customers and Suppliers
We are committed to fair trade with our customers and suppliers. We expect our employees to comply with the following matters regarding our customers and suppliers:
We may not mislead, misrepresent, deceive, or take unfair advantage of customers or suppliers.
“Even if it is in favor of the company, we must correct the mistake where we see it.”
We must monitor the Company procurement processes before appointing suppliers.
We must purchase from suppliers and sell to customers based on appropriate considerations, such as quality, price, reliability, sustainability, and commitment to human rights.
When purchasing good or services on behalf of the company, we must treat all potential suppliers equally and honestly.
We don’t say anything to suppliers that suggests our relationship with them may be affected by personal favors, gifts, donations to charity, etc. (See the Gifts, Entertainment, and Other Aid section in this regulation)
We may not offer gifts, entertainment, or aid to get or keep a job. (See the Gifts, Entertainment, and Other Aid section in this regulation)
The Company’s suppliers are required to comply with all applicable local and national laws, rules, regulations, and requirements when manufacturing and distributing our products and providing our services.
Customer health, safety, and satisfaction are our top priorities and we expect our employees to act in accordance with this principle.
We may not do anything that undermines the trust our customers place in us or compromises the quality or safety of our products or services.
8.PROTECTION OF COMPANY RECORDS, INFORMATION, AND ASSETS
8.1.Accurate Record Keeping
When it comes to preparing Company Records, honesty and transparency are our primary principles. Each of us is obliged to ensure that all information in our company records, including shift schedules, payroll charts, overtime forms, expense reports, service records, maintenance and repair records, including all reports that belong to ourselves, the unit we are in charge of, or the company is complete, impartial, accurate, up-to-date, and understandable. We can only accomplish this through the provision of information completed in line with Company policies, regulations, and control procedures.
8.2.Keeping Records
The proper creation, retention, and destruction of records are key elements in keeping accurate company records. The Company is obliged to keep its records in accordance with the principles set out in the retention programs as well as the law. These record retention programs determine the methods of destruction as well as how long the company records must be kept.
If we have any questions about the retention of the documents in our possession, we should consult the legal adviser/consultant before doing anything.
8.3. Company Assets
B y working for the Company, we give an undertaking to each other, our Company, and our shareholders that we shall protect and use our Company’s assets appropriately and for business purposes. These assets include physical property, intellectual property, IT systems, and the reputation of our Company.
Company assets include but are not limited to the following:
We must all comply with the following items:
9.Fraud Prevention
All fraudulent activity is strictly prohibited. The Company expects the following from its employees:
All kinds of forgery.
10.Protecting the Company’s Reputation
10.1.Political Activities
Each of us is free to contribute to the society in which we live by taking part in the political process, but we can only do so on our own behalf and on our own time.
Even if we do engage in political activities on our behalf and on our own time, we cannot use the Company’s resources, telephone, computer, email address, or other tangible and intangible assets for the publication of politically motivated articles.
10.2.Disclosures to the Media or Investment Analysts
The Company must provide the public with accurate and insistent information about our activities. We can only make public statements regarding the topics and matters on which we are authorized spokespersons.
If a media representative or an analyst contacts us about something related to the company, we should refer them to the Commerce Department.
10.3.Social Media/Internet and Electronic Mail Policy
Within the context of the abovementioned matters:
10.4.Information Security Practices
Employees must comply with Information Security Practices at all times.
10.5.Other
Our commitment to act ethically and honestly requires us to be a party to legitimate and authorized commercial transactions. We can never make a false claim, verbally or in writing, on behalf of the Company.
11.CONFLICT OF INTEREST
What is Conflict of Interest?
Conflict of interest occurs when personal interests conflict or appear to conflict with the interests of the Company, potentially challenging our ability to make objective decisions regarding the Company’s interests. Avoiding genuine conflicts of interest and situations that appear to be such allows us to earn and maintain the trust of our customers and other business partners, colleagues, and the public; therefore, we must pay attention to this. The Company expects employees to notify their Manager immediately in the event of potential conflict of interest.
We are each obliged to act in the best interest of the Company and to avoid actual, potential, or perceived conflicts of interest when managing company affairs.
11.1.Relationships Among Employees
Conflicts of interest mostly occur when there is a personal relationship between employees. While such relationships may not inappropriately influence the making of objective and sound business decisions, they could potentially have that effect. This is especially true in romantic relationships or when we have a direct or indirect reporting relationship with family members. In addition, we cannot do paid or unpaid work for the person we report to directly or indirectly, except for our work in the Company.
If we have a personal relationship that seems to affect our decision-making, we must immediately notify our manager or supervisor, the HR Department, or the Legal Adviser/Consultant.
11.2.Personal Gain from Corporate Opportunities
We cannot direct a third party to pursue any opportunity we learn about in connection with our employment or through the use of company property or knowledge without written approval from the company's legal adviser/consultant.
Company employees may not use Company facilities to conduct their private affairs.
11.3.Doing Business with Family Members While Working at the Company
We must be careful if one of our family members works for a company with which the Company does business or intends to do business. If we find ourselves in such a situation and our business requires us to make business decisions in connection with this company, we are required tin inform our department manager and/or the legal adviser/consultant and obtain consent before making such transactions.
11.4.Investing Outside the Company While Working at the Company
A conflict of interest may arise of we or one of our family members have a financial interest in any enterprise with which the Company does business or competes. The conflict of interest that may arise in such cases usually depends on the size of our investment, our role in the Company, and the business relationship between the Company and the other company. We are required to obtain written approval from the General Manager before making such an investment or upon learning that such a situation exists.
11.5.Working Outside While Working at the Company
We have to ensure that our interests and activities outside of our duties do not clash with our responsibilities in the Company. We cannot work outside without prior written approval from the Legal Adviser/Consultant and/or the General Manager. Regulatory clauses may be added to the service contracts concluded between the Company and the employee regarding being hired by a competitor, customer, or supplier of the Company, employed as a consultant, or not being a member of any organization, to be effective after they leave.
This is defined as doing business with the Company after the employment contract has expired, establishing a company with the Company personally, owning shares in a company, entering into a contractual commitment, obtaining representation, opening a dealership, or engaging in similar commercial activities. This practice cannot be done without the written approval of the Legal Adviser/Consultant and/or the General Manager.
12.ANTI-CORRUPTION
Whoever we do business with, be it a public institution/organization or commercial customer, bribery is strictly forbidden in the Company. Therefore, we must never get involved in bribery and we must apply all the anti-corruption laws and regulations, including those in the countries where we operate.
What this means is:
13.VIOLATION OF THE ETHICS AND CONDUCT POLICY
We must take the principles of this Policy seriously and strive to follow them diligently at all times. We must not forget that disciplinary action may be initiated for violations of international and/or local laws, Company policies, regulations, guidelines, or this Policy, possibly resulting in the termination of the employee’s employment/service contract.
In addition, we should be aware that the violating persons and the Company may face legal or criminal penalties.
We attach importance to the feedback and opinions of our stakeholders regarding the Policy. The channels given below and in the QTerminals Head Office Compliance Policies are used to communicate questions about this Policy and report those who violate the rules set out herein or suspicious situations that could damage our reputation and trust. Such communication will be treated in confidence and anonymously.
Communication Channels:
Head Office
Human Resources Department: ik@qterminals-antalya.com
Reporting Email Line: etik@qterminals-antalya.com
Online Application Form: https://www.qterminals-antalya.com/
QTerminals Ethics Platform: https://qterminals.com/
In cases where applications are not made anonymously, it is the responsibility of the General Manager to keep the details of the reporting parties confidential and to take the necessary steps to prevent them from being exposed to any negative situation regarding such notification. There shall be no retaliation against the employee who made the report.
13.1.Authority to Investigate Ethics Violations
The Ethics Violations Investigation team is responsible for investigating and examining all complaints and reports relating to violations of the Company's Code of Ethics and related policies. The Ethics Violation Investigation Team shall report directly to the General Manager. The General Manager shall appoint the Ethics Violation Investigation Team.
13.2.Principles of Investigating Ethics Violations
Investigations of ethics violations shall be carried out subject to the following principles:
The Company adopts a zero-tolerance approach toward violations of the Code of Ethics, failure to duly report violations of the policy, or retaliation against reporting parties. The Company may take internal disciplinary action against those who violate these rules or retaliate against those who report them.
14.EFFECTIVE DATE
The Policy and Policy changes shall become effective on the date they are published.
1.PURPOSE AND SCOPE
1.1.PURPOSE
The purpose of this Anti-Bribery and Anti-Corruption Policy (“Policy”) is to clearly state our approach to bribery and corruption as Ortadoğu Antalya Liman İşletmeleri Anonim Şirketi (the “Company” unless otherwise stated). This policy is implemented within the framework of SR10.2024 Article 8.7 for fair business practices and to prevent bribery, corruption, and conflict of interest risks. This Policy is implemented in full compliance with the Corporate Compliance Policies (Human Rights Policy, Code of Conduct, Third Party Code of Conduct, Anti-Bribery and Anti-Corruption Policy, Nondiscrimination Policy, Conflict of Interest Policy, Sanctions Policy, IT Security Policy, Data protection Policy, and Data Retention Policy, and similar global policies) published by the QTerminals Group (Head Office).
The policies published by the Head Office are an integral part of the principles set out in this document and are binding on QTerminals Antalya. In matters not explicitly stated in this policy text, Head Office Compliance Policies shall be taken as a basis.
Head Office policies are prepared in Turkish and English and published on the corporate website of Ortadoğu Antalya Liman İşletmeleri A.Ş. such that they are available to all stakeholders.
1.2.SCOPE.
The Company expects all its employees and business partners to act in accordance with the Anti-Bribery and Anti-Corruption Policy. This Anti-Bribery and Anti-Corruption Policy covers our fundamental principles regarding anti-bribery matters.
The persons/organizations to which this Anti-Bribery and Anti-Corruption Policy applies include the following:
This Anti-Bribery and Anti-Corruption Policy has been approved by the General Manager and is an integral part of the Human Rights Policy, the Ethics and Conduct Policy, the Discipline Regulation, the Occupational Health and Safety and Employee Handbook, the Quality Management Systems Policies, and the Human Resources Procedures and other regulations, directives, and/or policies.
The policies, procedures, and regulations, etc. described above shall be given to our staff and business partners up-to-date and without delay at the start of the business relationship.
2.DEFINITIONS.
This section briefly explains the special terms and phrases, concepts, and abbreviations expressed in the Anti-Bribery and Anti-Corruption Policy.
The Company shall have right to claim additional fees if: Ortadoğu Antalya Liman İşletmeleri A.Ş.
Management Team: Ortadoğu Antalya Liman İşletmeleri A.Ş. Department Head/Managers
Employee: Company Employees
Service Provider: Any company from which the Company receives and/or provides services (supplier, agency, subcontractor, customer, etc.), and its employees.
Public Official: Persons who have been permanently, contractually, or temporarily appointed or elected for the execution of public duties. “Public” refers to all state bodies performing public services.
Corruption: The abuse of the authority held by virtue of one’s position for the purpose of securing all kinds of gains, directly or indirectly. Corruption includes, but is not limited to, embezzlement, breach of trust, and other financially improper conduct, including:
Bribery: Providing others with benefits contrary to the requirements of one’s duty or due to this relationship by such means as procuring, offering, or promising a benefit, directly or through intermediaries, in order to do a job, have it done, not do a job, to expedite or retard a job related to the performance of a person’s duty; demanding, receiving, or arranging such.
Bribery and corruption may take place in many different forms, including the following:
3. RESPONSIBILITIES
3.1.General Manager
Is responsible for approving the Anti-Bribery and Anti-Corruption Policy on behalf of the Board of Directors and for determining, implementing, and overseeing the notification, investigation, and sanction mechanisms when the rules and regulations are violated. Shall perform his/her duties within the framework of the authority granted by the Board of Directors.
3.2.Audit Committee
The Anti-Corruption and Anti-Bribery Policy Audit Committee consists of officials designated with the written approval of the General Manager.
The duties and responsibilities of the Audit Committee have been prepared in accordance with the legal regulations, set down in writing, approved by the Board of Directors and publicly disclosed on our website. The Audit Committee is responsible for:
The Audit Committee has been given the duty and authority to conduct an independent assessment of the adequacy of the anti-bribery policy and/or its systems.
3.3.Management Team:
The Management Team is responsible for preparing, developing, executing, and updating this Policy. The team is answerable to the General Manager for the creation and publication of this Policy, and updating and repealing it when necessary.
The Management Team is responsible for enforcing and supervising the practices related to the Anti-Bribery and Anti-Corruption Policy. The Management team is also responsible for taking the necessary measures for employees and external service providers to comply with this Policy and for reporting any matters contrary to the Policy to the General Manager for investigation.
Management Team is comprised of the Department Head and Managers.
3.4.Legal Adviser/Consultant
The Legal Adviser/Consultant evaluates the Anti-Bribery and Anti-Corruption Policy in terms of its currency and improvement needs and, when necessary, may make recommendations to the Management Team.
3.5.Employees and Managers
All employees and managers shall accept the Anti-Bribery and Anti-Corruption Policy and act in accordance with the principles in the policy text and the related laws and regulations and all anti-corruption laws in force.
Employees are responsible for adhering to Company policy, regulations, and procedures, ensuring compliance with the same, and working in compliance with the legislation in force.
All employees are responsible for reporting conduct, activities, or practices in contravention of the Policy when they encounter such using the designated communication channels.
Employees cannot be forced by anyone under any circumstances to act in contravention of this Policy. There shall be no retaliation against or punishment of employees who do not give bribes.
Managers shall ensure that the principles in the Policy text are understood, practiced, and maintained by business partners they are responsible for and the employees under their supervision.
Managers are obliged to report all complaints, tip-offs, and allegations made by their subordinate employees via the designated communication channels.
3.6.Selection of External Service Providers and Business Partners and Securing Agreements
External Service Providers and business partners must comply with the principles of the Anti-Bribery and Anti-Corruption Policy and other related regulations. All commercial relations with non-compliant persons or organizations shall be terminated.
When selecting the companies and business partners from and to whom goods and services are provided, consideration shall be given to such criteria as experience, financial performance, technical adequacy as well at ethical conduct and having a positive history in this area. Companies or business partners with a negative history of bribery or corruption shall not be worked with even if they meet the other criteria. Responsibility for conducting the necessary research and assessments prior to entering any business relationship in this regard lies with the General Manager.
3.4.Human Resources Department
Human Resources Department is responsible for taking all necessary measures during human resource processes (recruiting, communication, training, etc.) to ensure compliance with the policy and for distributing them internally.
4.OUR ANTI-BRIBERY AND ANTI-CORRUPTION PROGRAM AND OUR COMMITMENTS
As a company, we have adopted the principle of complying with the national laws and regulations on bribery and corruption everywhere we operate, as well as universal legal rules, and ethical and professional principles, particularly, the OECD Convention on the Prevention of Bribery of Public Officials in International Commercial Transactions.
We carry out activities aimed at fulfilling the following matters covered by the Anti-Bribery and Anti-Corruption Policy and taking the necessary measures:
4.1.Receiving and Offering Bribes
The Company is opposed to all forms of bribery and corruption and is committed to complying with related laws, regulations, and principles. The giving and taking of bribes for whatever reason is strictly prohibited.
Zero Tolerance
As a company we act with a “ZERO TOLERANCE” approach toward bribery and corruption in line with this principles and we are committed to continuing our activities in a fair, honest, transparent, legal, and ethical manner. This Anti-Bribery and Anti-Corruption Policy has been implemented as a requirement of the importance we attach to this topic.
Since the matter is a legally punishable act as well as a matter of business ethics, we expect our employees to be mindful about this matter and to consider it part of their personal duties and responsibilities outside of their working life.
4.2.Facilitation Payments
The Company forbids all forms of payment aimed at facilitating or expediting any job,
In their relations with third parties, Company employees show no tolerance toward the other party offering, promising, soliciting, requesting, giving, or accepting a bribe.
4.3.Representatives, Suppliers, Customers, Agencies, and Business Partners
The Company shall enter into business relations with Representatives, Agencies, Suppliers, Customers, Contractors, and Business Partners that are deemed to safeguard the Company’s reputation and work in accordance with the Company’s Anti-Bribery and Anti-Corruption Policy.
No benefit of any kind should be requested from suppliers, agencies, dealerships, authorized service points, or customers and any such offers should be declined.
The Company shall not do business with individuals or companies included on blacklists created in line with information received from public authorities, international data providers, and social media sources to ensure compliance with the applicable regulations and the Company’s own rules. The Company shall create and disclose a blacklist of those with whom it will not do business.
4.4.Gifts and Hospitality
When conducting relations with private or public persons and organizations that want to establish or maintain a business relationship with the Company, no gift or hospitality that could create the impression of impropriety or that may cause or be perceived as a dependency relationship, other than generally accepted promotional materials, may be offered or accepted.
4.5.Relations with Public Organizations
Without the necessary approvals (gifts, hospitality, etc.), it is forbidden to offer, promise, or give gifts, hospitality, treats, or any other benefit to foreign or domestic public institution employees either directly or indirectly.
In addition to this, our employees may not, directly or indirectly, give bribes to public officials to gain benefits in public affairs. This is why our employees are obliged to act in compliance with the Anti-Bribery and Anti-Corruption Policy Company.
4.6.Recruitment:
For any job offer made by the Company not to give the impression of bribery and corruption, it must be made as part of the competitive recruitment processes set out by the Company’s procedures.
4.7.Donations, Charity, and Sponsorships@
Politically motivated donations cannot be made on behalf of the Company. If a compliance audit, internal audit, or statutory audit discover that a donation/political donation has been made in contravention of the policy, this situation shall be made public.
Charitable contributions and sponsorships made by the Company must be lawful and in accordance with the Company regulations, policies, directives, and regulations and comply with the local laws in force.
5.Record Keeping
The matters with which the affiliates included within the organization of our Company are obliged to comply in relation with the accounting system have been set out within the framework of the relevant legislation and regulations.
6.Training and Communication
We ensure that all Company employees and contractors, suppliers, agencies, and business partners are informed about anti-bribery and anti-corruption matters and that the relevant parties receive training to assimilate the principles of this Policy.
A training and awareness program concerning the legal requirements related to the anti-bribery and anti-corruption program is given to employees and business partners.
Safe and accessible communication channels are established over which employees can report suspicious situations.
7.REPORTING BRIBERY AND CORRPTION VIOLATIONS
It is the responsibility of everybody mentioned above to report any situation concerning violation of the anti-bribery and anti-corruption rules to protect the Company’s reputation.
Ignoring or failing to report acts of bribery and corruption when noticed to the relevant authorities shall be considered a violation of the anti-bribery and anti-corruption rules.
We attach importance to the feedback and opinions of our stakeholders regarding the Policy. The channels given below and in the QTerminals Head Office Policies are used to communicate questions about this Policy and those who violate the rules set out herein or suspicious situations that could damage our reputation and trust. Such communication will be treated in confidence and anonymously.
Communication Channels:
Head Office
Human Resources Department: ik@qterminals-antalya.com
Reporting Email Line: etik@qterminals-antalya.com
Online Application Form: https://www.qterminals-antalya.com/
QTerminals Ethics Platform: https://qterminals.com/
In cases where applications are not made anonymously, it is the responsibility of the General Manager to keep the details of the reporting parties confidential and to take the necessary steps to prevent them from being exposed to any negative situation regarding such notification. There shall be no retaliation against the employee who made the report.
7.1.BREAKING THE ANTI-BRIBERY AND ANTI-CORRUPTION RULES AND THE CONSEQUENCES
All our employees and all business partners as described above must know the rules in the Policy and, when conducting their business, must act in compliance with these rules and the anti-bribery and anti-corruption legislation in force.
Ignorance of the rules in this Policy is not an acceptable excuse for breaking them.
In cases where this Policy is violated, disciplinary action that can go as far as terminating the employment contract, depending on the severity of the incident, shall be applied.
In addition, those who do not comply with the relevant legal regulations and all applicable anti-corruption laws may be subject to criminal liability.
Employees or business partners shall not be exposed to any negative consequences as a result refusing to participate in bribery or corruption or reporting an act of bribery or corruption. In such cases, one must apply through the reporting channels specified in this Policy.
8.MONITORING, INSPECTION, and IMPROVEMENT PROCESS
This Anti-Bribery and Anti-Corruption Policy shall be reviewed at regular intervals by the Management Team and its practices shall be monitored regularly and assessments reported annually to the General Manager. Bribery and corruption issues are included in the general risk-based assessment processes and regular risk assessments in this area are carried out annually with controls implemented to eliminate corruption risks.
The Management Team regularly reports to the General Manager regarding the effectiveness of the anti-corruption program.
9. Policy Violations
In cases that are or are likely to be in violation of the Policy, the matter shall be examined by the Management Team and reported to the General Manager so that the necessary sanctions can be implemented if misconduct is detected.
10. Support and Protection of Staff Acting in Accordance with the Policy
The Company shall guarantees that the staff who operate the anti-bribery and anti-corruption rules shall not be harmed in any way for following the rules, that staff who act in accordance with the policy shall be protected under all circumstances, and that the notifications made to the relevant units and persons in this regard shall be kept confidential.
11.EFFECTIVE DATE
The Policy and Policy changes shall become effective on the date they are published.
