Our Policies

OUR POLICIES

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.

Quality Management and Customer Satisfaction Policy

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

  • It responds to the technical and economic demands of our customers on time and at the desired quality level, thus ensuring continuity of communication with the customer and customer satisfaction.
  • It ensures that the services offered at the port can be provided at a professional level.
  • It creates a suitable manoeuvre area for the cargo and the ship in the operational process of the services given to the passenger and the cargo.
  • It continuously improves the effectiveness of Quality Management and Customer Satisfaction in accordance with the needs determined in accordance with the purpose of the Company.
  • It ensures that the principles of Quality Management and Customer Satisfaction are adopted and accepted by the employees.
  • It meets the training needs of the employees, whom they see as the most valuable resource, to increase their qualifications and professional experience in order to transform quality awareness into a corporate culture.
  • It supports the strategic direction of the organization in accordance with its purpose and context, it determines the quality objectives.
  • It enables our customers to transmit all their requests and complaints quickly and easily through all our communication channels, it demonstrates a customer-oriented, fast, objective, and attentive attitude while fulfilling these demands and complaints.
  • It offers solutions in the process of handling complaints by reviewing them taking into consideration the principle of personal data protection and confidentiality in light of created policy and objectives and in compliance with legal requirements.
  • It ensures that all activities and all services provided are carried out in accordance with legislation and in a way that fulfills customer requirements, in line with safe, secure, and environmental protection standards.

Environmental and Energy Management System Policy

QTerminals Antalya is aware that it carries out operations that impact the natural environment given its sector and field of activity. It has adopted the principle of carrying out operations that minimize the possible short- and long-term environmental impacts that may arise in connection with the operations it carries out, while at the same time protecting the regional, national, and international environment by ensuring that energy is managed correctly.

Within the scope of the Environment Management System and Energy 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 14001:2015 and TS EN ISO 50001:2011 certification respectively by the TSE,

which is why, in the name of protecting Antalya's environment and correct energy management, QTerminals Antalya

  • Has adopted a working approach that seeks ways to protect natural resources by minimizing the environmental impact of its operations.
  • It has a structure that complies with national and international environmental and energy legislation relating to all activities carried out in the enterprise, adopting best practices and standards in matters not regulated by laws and regulations.
  • With the service policy provided by using technologies that will not cause environmental pollution, it has adopted the principle of maximizing the effective use of energy by increasing energy efficiency and managing energy expenses with a professional understanding.
  • The main agenda of its process-based analyses, which are revised every year, is to reduce the use of products and services that are likely to cause pollution to the environment and to eliminate them as much as means allow.
  • The main goals and real objectives of the enterprise include the prevention of pollution, sustainable resource use in the context of the organization, prevention of climate change by reducing greenhouse gas emissions due to energy management, and protection of the marine environment ecosystem.
  • All public and private sector persons, legal persons and business partners, customers, QTerminals Antalya employees, and all members of society all bear the responsibility for producing solutions in the name of protecting the environment by acting together.
  • To effectively implement the QTerminals Antalya Environmental and Energy Management System Policy, all employees guarantee that they are familiar with these rules and regulations, and when necessary, these rules are supported by training with areas of responsibility and obligations being allocated to each unit.

Health and Safety Policy

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:

  • Health and Safety should be considered a priority in the planning, operation, and decision-making processes.
  • All transactions should be processed with the best methods, techniques, and practices in accordance with all Occupational Health and Safety legislation (laws, regulations, and regulations) in force in our country, taking into account the exigency of the laws.
  • All security hazards have been identified within the scope of risk assessment and existing risks have been reduced or eliminated as means allow. The risk assessment is reviewed annually and can be revised during the year if conditions change.
  • All employees have been duly informed and trained and have a solid grasp of the subject of Health and Safety. In addition, the necessary leadership and guidance are provided out by the relevant units and qualified personnel.
  • It is the common responsibility of all our employees to comply with the occupational health and safety rules in the environment where they work, to inform their immediate supervisor of any negative situation, and to provide added value by taking part in Health and Safety exercises.
  • Effective cooperation, consultancy, and communication channels are available between management, port users, and employees to ensure, review, improve, and protect safety.
  • In the event that any employee has any concerns/trepidation regarding the Health and Safety Policy, the necessary environment has been created and supported for them to share the issue with the necessary authorities in good faith without trepidation.
  • The procurement and design of all infrastructure and superstructures, ships, goods, supplies, and materials must meet the necessary safety and health conditions and comply with high-level safety rules.
  • QTerminals Antalya management has ensured that its personnel work in a safe, healthy, and comfortable environment, taking into account the situation and conditions of the port.
  • All accidents, safety incidents, and events are carefully investigated.
  • According to the business plan, health and safety objectives should be addressed holistically across management, partners, and departments. Duties and responsibilities need to be allocated to certain management levels to achieve the intended goal.
  • The Safety Management System is monitored, reviewed, and compared at specific intervals.
  • Sufficient resources plus available and necessary expert support have been provided to be able to implement this Policy, and synergy and cooperation have been created with the help of consultants.
  • The Health and Safety Policy will be reviewed annually and the annual reports will be kept and published following performance evaluation.
  • QTerminals Antalya Health and Safety Policy regulations and procedures are shared with the relevant institutions and organizations in written and visual form.

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

  • Together with the ISO 9001 Quality Management System and ISO 14001 Environmental Management Systems.
  • The ISO 45001 Occupational Health and Safety Management System and policies, as well as national and international legislation provisions on the transport of dangerous goods by sea, are aimed at.
  • Preventing accidents arising from hazardous materials, the necessary training is given to all employees in the organization including subcontractor employees, and run in collaboration with subcontractors.

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:

  • Identification of personal data subject to disposal.
  • Identifying the relevant users for each personal data using an access authorization and control matrix or a similar system.
  • Determining the authorizations and methods for the relevant users such as access, retrieval, and reuse.
  • Closing and removing the relevant users' authorization and methods of access, retrieval, and reuse within the scope of the personal data.

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.

In light of the mission, vision, values, and strategic quality targets it has set, QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) has adopted as its basic principle to keep the health and safety of its employees, customers, stakeholders, and the environment it is in contact with at the highest level and to ensure the continuity of all these principles.

The outbreak of the Covid-19 (SARS-CoV-2) virus, which was described as a pandemic by the world health organization on 11 March 2020, has caused millions of infections and hundreds of thousands of deaths. Covid-19 pandemic: it builds on the best evidence from previous pandemic periods such as influenza, sars, and mers, and considers preparedness, implementation, and other measures, focusing only on the aspects of prevention and control of diseases that spread through droplets and contact.

Within the scope of our policy prepared in line with national and international norms in the port sector, with the awareness that every precaution we take in our workplaces, as the most important places where people come together and come into contact with large numbers of people, will have important effects on the protection of not only our employees but also their families and the whole society:

  • In the name of continuing and maintaining the operational process, we have adopted the following as our basic principles: Ensuring that the hygiene practices of all official institutions relating to protection from the COVID-19 pandemic starting with the T.R. Ministry of Health are implemented in the Port Area by taking in consideration their recommendations for the prevention and control of the infection.
  • Assisting in the prevention of infection at the institutional level with administrative controls and controlling and limiting the transmission of infection.
  • Identifying and supplying the resources needed for the establishment, implementation, and continuity of hygiene, infection prevention, and control, and delivering them to those in need.
  • Conducting a risk assessment covering all physical areas and all relevant parties against COVID-19, then ensuring the continuity of the action plans prepared for Hygiene, Infection Prevention, and Control according to the results of this risk assessment.
  • To guide personnel, customers, and visitors correctly in accordance with the hygiene rules by complying with the obligations relating to the relevant legislation (Occupational Health and Safety Law, Public Sanitation Law, etc.) to control the risk of hazards adequately where exposure cannot be avoided.
  • Informing all port workers including subcontractors about COVID-19 and briefing them on infection prevention and control procedures.
  • Raising the awareness of employees and all stakeholders so that the principles of hygiene, infection prevention, and control can be applied to all other collective living spaces.
  • Encouraging employees with chronic diseases, spouses or children with similar health problems, and disabled employees whose health may be at risk to work from home and remotely with the knowledge of department managers, human resources, and the workplace physician.
  • Sending employees who may have a suspicious condition (showing symptoms, or a person with someone in their family or immediate environment diagnosed with COVID-19) to their homes or relevant health institutions.
  • Managing the isolation, evacuation, and transfer procedures of possible COVID-19 cases within the limits of the port in line with the directions of the workplace physician and defined action plans.

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

  • Explicit consent of the data subject.
  • Clearly stipulated in the laws.
  • A person who is unable to disclose his consent due to actual impossibility or whose consent is not granted legal validity is mandatory for the protection of the life or body integrity of himself or another.
  • Processing of personal data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or execution of the contract organized as a result of approval and/or signature with QTerminals Antalya.
  • Must be mandatory for QTerminals Antalya to fulfill its legal obligation.
  • Be made public personally by the person concerned.
  • Data processing is mandatory for the establishment, use, or protection of a right.
  • Data processing is mandatory for the legitimate interests of QTerminals Antalya, provided that it does not damage the fundamental rights and freedoms of the person concerned.) And again 6. İn the context of the item.

 

  • Explicit consent of the data subject.
  • It is processed within the terms and purposes of personal data processing specified in other cases provided for by law.

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;

  • Learning whether it is processed.
  • Request information if it has been processed.
  • Learning the purpose of processing and whether it is used according to its purpose.
  • Transitioned at home or abroad 3. knowing people.
  • Request correction if it is incomplete / incorrectly processed.
  • Request the deletion, destruction, or anonymization of personal data in case of the disappearance of reasons requiring the processing of personal data.
  • 3. Request notification of transactions against persons in accordance with paragraphs (5) and (6) listed above.
  • Objecting to the occurrence of a result against you due to its analysis exclusively with automated systems.
  • Has other rights written in the legislation and to demand the removal of the damage in case of damage due to its unlawful processing.

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 uyildirim@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

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 organisations 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

Company: QTerminals Antalya

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 behaviour, 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 organisations 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, colour, 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, organise, and conduct collective bargaining within the framework of unions recognised 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, minimise, 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 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 organisations, 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

Human Resources Policy

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;

  • Participation of our employees in our processes with a participatory, transparent, and fair management approach.
  • Ensuring equality of opportunity.
  • First referring to our existing employees for open positions.
  • Ensuring the continuity of the organizational structure, which can be quickly adapted to innovations and development.
  • Establishing a continuous and learning structure from each other, to develop and to ensure its operability.
  • Ensuring the continuity of the understanding to find the right person for the right job, the right job for the right person.
  • Planning human resources with the qualified workforce to ensure effective and efficient functioning of the organization.
  • Increasing the professional/personal knowledge, skills, and competencies of the employees through continuous training and development programs.
  • Participation in joint work with Universities, Vocational Colleges, Institutions, and Non-Governmental Organizations.
  • Demonstrating a sensitive approach to Occupational Health and Safety in accordance with quality policies and standards.
  • Dopting social responsibility awareness in all applications, participating and encouraging.
  • Further strengthening our profile of employees who respect the environment and nature.

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. SCOPE

This Policy covers the managers and employees of QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) at all levels.

2. DEFINITIONS

Special terms and phrases, concepts, and abbreviations in this Ethics and Behaviour Policy are briefly defined.

General Manager: QTerminals Antalya General Manager

Management Team: Consists of Department Managers and Managers

Company: QTerminals Antalya

Employee: Company's Employees

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

3. RESPONSIBILITIES

3.1. General Manager:

The General Manager is responsible for the approval of this Policy, determination and operation of notification, inspection, and sanction mechanisms in case of failure to comply with the rules and regulations. On behalf of the Company Board of Directors and with the authorisation from the Board of Directors, it executes the Ethics and Behaviour Policy and ensures it is carried out.

3.2. Management Team:

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

3.3. Employees:

Employees:

  • Adhere to and comply with company policies, regulations, and procedures.
  • Work in compliance with the current legislation.
  • Are responsible for notifying the Department Manager to which they are affiliated in case of any behaviour, activity, or practice contrary to this Policy.

3.4 Health, Safety, Environment and Quality Department:

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

3.5. Human Resources Department:

The Human Resources department is responsible for the internal distribution of this Policy and the continuity of its implementation.

4. BUSINESS PRINCIPLES

The prestigious image and corporate brand created by the Company during its operations are its most valuable assets. The basic business principles that all our employees must comply with in their activities to protect and improve our corporate reputation are listed below. The Company expects all managers and employees while continuing their activities to understand and adopt the values ​​and ethical principles of the Company and to act in accordance with the way the Company does business.

4.1. Expectations of Employees:

Without compromising their values, our Employees:

are to use the Ethics and Behaviour Policy as a guide in our relations with all our stakeholders, including colleagues, managers, officers, business partners, suppliers, public institutions and organisations, and non-governmental organisations, to read and understand the Code of Ethics and Behaviour to better understand the behaviour expected of them, and to be aware that the Company is obliged to know and act in accordance with all policies, procedures, and regulations, and all laws and regulations concerning the task performed.

4.2. Expectations of Managers:

Our managers:

  • Should communicate about Ethics and Compliance issues.
  • Should ensure that their personal actions set an example for employees in accordance with the behaviour expected of managers.
  • Sshould provide an open communication environment that encourages employees to ask questions and raise concerns.
  • Should report known or suspected ethics issues or abuse to a senior manager.
  • Should respect the identity of employees participating in investigations or voicing their concerns and doubts, reporting as much as possible and within the scope of the law.
  • They should prevent any retaliation against employees who raise their concerns and doubts, or any behaviour that may be perceived as retaliation by others, and never compromise on this issue.

4.3. Making Ethical Decisions:

This Ethics and Behaviour Policy allows us to assist us in identifying and resolving potential problems. We must decide whether an action we find difficult to decide is appropriate and ethical and in case of any hesitation, we must not take action under the guidance of this Policy, we must carefully review the parts of the Ethics and Behaviour Policy or other relevant policies of the Company and talk to our manager to seek help from her/him.

4.4. WORKING ENVIRONMENT:

Fair Work Environment

  • The Company believes in and supports the rights and freedoms of people everywhere it operates.
  • Accordingly, the Company does not discriminate under any circumstances, regardless of religion, language, race, sect, age, colour, nationality, social origin, political opinion, philosophical belief, dress, and association membership, physical disability, or gender. This also applies to recruitment and promotion, the working conditions provided, and all relationships with customers, suppliers, and partners.

The Company is obliged to ensure that the working conditions and the products and services they produce are suitable for human health and safety.

Every employee has the right to receive fair, polite, and respectful treatment from his/her subordinates, superiors, and colleagues. By creating a fair, healthy, and safe working environment where employees are respected and that complies with all relevant legal regulations, the performance, development, and loyalty of the employees will be increased.

4.5 Respectful Workplace, Harassment, Bullying, Threats, and Misconduct

Providing our employees with a work environment free of harassment, bullying, threats and other inappropriate behaviour is one of our primary duties.

There is no tolerance in the Company for harassment, bullying, or threats. The Company does not tolerate such behaviour, regardless of whether an allegation of harassment, bullying, or threats can be enforced under local law.

Some Examples of Harassment:

  • Unwanted sexual advances, any request for sexual intercourse in return for anything, and other sexual acts, verbal or physical.
  • Disturbing speeches, jokes, pictures, and comments regarding race, colour, gender, sexual orientation, gender identity, age, religion, sect, nationality, disability status, veteran status, and other characteristics protected by law.

Some Examples of Misconduct

  • Shouting or screaming in anger.
  • Name-calling.
  • All kinds of abuse.
  • Sarcastic, obscene speeches, correspondence.
  • Threats and intimidation.
  • Mocking/teasing in public.
  • Intentionally excluding someone from a group.

4.6. Confidentiality

Confidential information is topics and similar information arranged within the scope of confidentiality agreements executed especially with third parties and all kinds of financial, strategic, technical, and commercial information belonging to the company and unknown by third parties, which may cause damage to the company and/or its stakeholders or benefit others if disclosed.

All employees are expected to take care to protect the information of the Company and all its stakeholders. Employees should only share this information with the relevant persons within the specified authorities.

Confidential information should not be shared with third parties when leaving the Company. Employees must submit all kinds of documents or electronic copy documents that belong to the Company and that they receive during the working period.

Our newly recruited employees should not share confidential information about their previous employers within the Company.

All official statements are announced simultaneously to investors, partners and the public through the units determined by the Company.

Company employees are expected to protect confidential financial information attributable to the Company, trade secrets, information and documents regarding personnel rights or agreements made with business partnerships that may weaken the competitive power of the Company and similar information and documents, and to protect the confidentiality of such information.

Company employees are expected to refrain from sharing information obtained or owned with unauthorised persons, internal or external authorities, or using it for speculative purposes (directly or indirectly).

Company employees are expected to refrain from the use of non-public information belonging to the institutions, organisations, companies, and their customers with whom they do business, other than for the specified purposes, or to share them with third parties without obtaining the necessary permissions.

4.7. Leaking Information

Employees should refrain from transmitting any confidential information belonging to the Company to third parties, and third parties should refrain from the purpose of obtaining commercial income from the direct or indirect purchase or sale of securities on the stock exchange by relying on such confidential information.

Employees' behaviour in contravention of this principle is in no way binding on the Company. Employees will be personally responsible for all consequences of acts contrary to this article. They also need to be fully aware that confidential information trading is illegal. In addition, violation of this article will also constitute a violation of the employment contract of the employee, and such behaviour should not be performed under any circumstances.

4.8. Confidentiality of Employee Information

Our relations with our colleagues and our company are built on mutual trust and respect. To maintain these relationships, each of us must exercise due diligence to keep employee personal information confidential. We must achieve this by applying company policies, regulations, and control procedures and by complying with the necessary regulations.

We cannot access any system, database or records containing personal information of current or former employees without the necessary approval and permission.

Those of us who have access to the personal information of employees are obliged to be cautious before disclosing this information. Employment records can only be disclosed as permitted by law, and this disclosure can only be made after the approval of the Company Managing Director. We may provide this information to another employee of the Company if he or she has to report them for important and legitimate business reasons. Health records of employees are private and confidential, health records can only be disclosed in cases where required by law or with the written consent of the relevant employee.

4.9. Safety and Security in the Workplace 

Each of us has the right to work in a safe and secure work environment, and we are all obliged to support its achievement and to protect ourselves and our colleagues. We must follow safety policies and procedures and report work-related injuries or illnesses and unsafe working conditions to our administrative managers, Health, Safety, Environment and Quality department immediately. We are also obliged to know the Emergency Action Plan of our location.

Providing a safe work environment also minimises the possibility of violence in our company's work area or when conducting business on behalf of the company. For this purpose, our employees cannot perform the actions listed below.

  • Engaging in workplace violence, including threats, threatening behaviour, harassment, intimidation, assault, and any such behaviour.
  • Carrying weapons at our location without the written approval of the Human Resources department.

We must also be mindful of and report the presence of strangers or unusual activities that could lead to theft or damage to company property or employees. We should report our security concerns, incidents, or suspicious activities to our manager or Human Resources Manager as soon as possible.

The following are the most essential duties of the Company and each employee:

  • To ensure that security is the basis of our values.
  • To integrate our belief that injuries and diseases occurring in the workplace are preventable through our actions.
  • To provide a workplace that complies with or is superior to current occupational safety and regulations.
  • To create occupational safety and technical guidelines based on best practices.
  • To strive to continuously improve our occupational safety performance.
  • To expect all Company employees to contribute to security improvements.
  • To follow and identify the elements that pose a risk/threat to human health in all activities of the Company, despite taking precautions.

4.10 Drugs and Alcohol

To maintain a safe and efficient work environment and to provide the highest quality service to our customers, it is very important that we can think clearly and react quickly. For this reason, we cannot use, keep, or sell alcohol or illegal or unapproved (without a doctor's report) drugs or stimulants during working hours within the Company or while conducting business or traveling for this reason.

The only exception to this rule is the limited use of alcohol at business meals or at management-approved company events. In such cases, we must strictly comply with applicable alcohol consumption laws, if any.

4.11. Smoking at Work

Smoking in the workplace or indoors is determined by legal regulations. The Company may restrict smoking in the workplace due to other reasons such as workplace health and safety requirements or employee demands, and it expects its employees to comply with these restrictions and legal regulations, although it is not necessarily included in the legal regulations.

5. RESPONSIBILITIES TO THE ENVIRONMENT AND SOCIETY

5.1. Social Responsibility

As a Company, we always attach great importance to close cooperation with the communities we live in and with our social stakeholders, in line with our basic strategy. In this context:

It is among our basic principles to support efforts that will contribute to economic and social development, to be sensitive to the issues of society and to support development efforts.

5.2 Responsibility to the Environment

By working on behalf of the company, we are committed to protecting the environment and respecting the communities where we do business. This requires us to respect our environment in a way that fulfils or exceeds the requirements set by the applicable environmental laws and regulations, as well as workplace safety and worker health policies.

We expect all our employees to be responsible citizens and environmental protectors by complying with environmental laws, regulations, and standards.

We expect our employees to read, understand and implement the Company's 'Environment and Energy Management System Policy'.

6. Human Rights and Compliance with law

Our Company is obliged to act in accordance with the laws in the fields in which it operates. Our employees are not allowed to do unlawful work, thinking that it will serve the company or personal interests. The Company's Legal Advisers/Consultants are consulted if there is any doubt in the legal field about the work done.

We are determined to conduct our business with an attitude that respects and develops human rights based on our values ​​and working principles. We support human rights always and everywhere regardless of local business traditions.

We expect our employees to read, understand and implement the Company's 'Human Rights Policy'.

We expect our suppliers and business partners, as well as our employees, to comply with these standards to protect human rights:

  • Opposition to child labour.
  • Opposition to forced labour and abuse of the workforce.
  • Prohibition of discrimination.
  • Compliance with working hours, wage, and rights laws.
  • Provision of safe and secure conditions for employees.
  • Protection of the environment.
  • Opposition to and prohibition of bribery and corruption.
  • Compliance with constitutional organisation and collective bargaining rights.

7. Customers and Suppliers

We are committed to fair dealing with our customers and suppliers. We expect our employees to comply with the following issues regarding our customers and suppliers.

We cannot mislead, misrepresent, deceive, or gain unfair advantage over customers or suppliers.

'Even if it is in favour of the company, we should correct the error where we see it',

We must follow Company purchasing processes before assigning suppliers.

We must purchase from suppliers and sell to customers based on appropriate aspects such as quality, price, reliability, sustainability, and commitment to human rights.

We must treat all potential suppliers equally and honestly when purchasing goods or services on behalf of the company.

We cannot make a statement to suppliers that means that our relationship with them may be affected by personal favours, gifts, donations to charities. (See the Gifts, Entertainment and Other Benefits section in this regulation).

We cannot offer gifts, entertainment, or assistance to get or retain a job. (See Gifts, Entertainment and Other Aids section in this regulation)

Company suppliers are required to comply with all relevant local and national laws, rules, regulations, and requirements in the production and distribution of our products and supplies and the provision of our services.

Customer health, safety, and satisfaction are our top priority, and we expect our employees to act in accordance with this principle.

We cannot do anything that could damage our customers' trust in us or the quality or safety of our products or services.

8. Protection of Company records, information, and assets

8.1. Accurate Record Keeping

Honesty and transparency are our primary principles when it comes to the preparation of Company records. Each of us is obliged to ensure that all information in our Company records, including all reports, shift schedules, payroll charts, overtime forms, expense reports, service records, and maintenance and repair records belonging to ourselves, the department or company we are responsible for are complete, impartial, accurate, up-to-date, and understandable. We can only achieve this through the presentation of information completed in accordance with Company policies, regulations, and control procedures.

8.2. Keeping Records

The proper establishment, retention, and destruction of records is an important element in keeping accurate Company records. The Company is obliged to keep its records in accordance with the principles specified in the retention programs as well as the laws. These record-keeping programs determine the duration of the Company's records as well as the methods of destruction.

If we have any questions regarding the retention/keeping of the documents we have, we should contact the Legal Consultant/Adviser before anything is done.

8.3. Company Assets

As we work for the Company, we make a commitment to each other, our Company, and our shareholders that we will protect our Company's assets and use them appropriately and for business purposes. These assets include physical property, intellectual property, information technology systems, and our Company's reputation.

Company assets include, but are not limited to:

Construction machinery, marine vehicles, all kinds of equipment, machines, vehicles, and spare parts

Inventory and assets

Phones, copiers, and fax machines

Computers, laptops, televisions, cameras, cell phones, tablets, printers and other technology resources and content and files.

E-mail and internet access systems and tools,

Confidential information and records

Inventions and ideas

Trademarks, copyrights, and patents

Trade secrets and plans

Receivables,

Business Relations

Reputation

Each of us must comply with the following articles:

We must use these assets responsibly, always respect and protect the Company's reputation, to ensure that company assets are not misused or wasted.

We must properly manage budgets, expenditures, and other funds.

We must comply with Company travel rules and spending policies, regulations or guidelines that are designed to maximise efficiency and reduce costs.

We must pay attention to security processes and be alert to situations that could lead to the loss, theft, or misuse of Company assets.

We must not allow anyone else, including our friends or relatives, to use company assets. (For company vehicle use, see 'Company Vehicle Delivery and Use Instruction')

While working on the Company computer, we must always use our own ID and password, and never give our password to anyone else.

We should not rely on questionable content delivered by e-mails.

We must always store corporate information on the corporate file servers or Document Management Systems. Only these fields are backed up.

Only properly licensed software may be used on Company computers and mobile devices. Unless permitted by the software license, the software should not be copied from one device to another.

We must treat Company assets with care and avoid use that could result in loss or damage.

If we are going to leave the computer, we must lock our screen and make sure that confidential information classified in our workspace is securely stored.

9. Fraud Prevention

All fraudulent activities are strictly prohibited. The company expects its employees to:

Act with honesty and integrity when using company materials, resources, and financial reporting systems.

Not make any cash/monetary transactions with unconfirmed/unverified methods, relying solely on a single source of information.

We must prevent, detect, and report fraud.

Below are some examples of fraud:

Stealing, mediating, or giving way to cash, inventory, products, or other assets.

Using company resources to purchase equipment, services, or materials to be used personally.

Receiving money or gifts from suppliers in exchange for business with the Company.

Submission of false or misleading requests for a refund.

Deletion of recoverable assets or receivables.

Use of company assets for personal interest.

Loss of a sale before it is made or earned.

Giving wrong information about working hours.

Making invalid entries in the accounting system.

Payment or receipt of payments for goods or services that are not received, different from contracts.

Paying or receiving payments for unworked hours or unrealised or undocumented expenses.

Forgeries of all kinds.

10. PROTECTING COMPANY REPUTATION

10.1. Political Activities

Each of us is free to contribute to our societies by participating in the political process, but we can only do so in our own behalf and in our own time.

Even if we do engage in political activities on our behalf and at our own time, we cannot use Company resources, telephone, computer, e-mail address and other tangible and intangible assets for political activities or publishing political articles.

10.2. Statements to Media or Investment Analysts

Providing correct and consistent information about our activities to the public is important for the Company. We can only make a public statement regarding the subjects and issues that we have authorised as spokesperson.

If a media representative or an analyst contacts us about a company-related issue, we should refer her to the Commerce Department.

10.3 Social Media/Internet and Electronic Mail Policy

  • Employees should only use internet access and electronic mail receiving/sending for business purposes.
  • The Company's internet access and electronic mail system is a company resource, and the Company has the right to read, monitor, and copy the internet usage and e-mails.
  • Employees must take sufficient care not to disclose confidential information and to obtain illegal information.

Within the framework of the situation mentioned above:

Social media channels are an important method of personal and business communication. However, we must be sensitive and careful when posting or sharing online.

There should be no expectation of privacy on social media channels we enter while at work or using Company equipment. We must comply with social media restrictions in the workplace.

Only authorised employees can use social media on behalf of the Company. Those who are not authorised cannot write the agenda on behalf of the Company and cannot communicate/share using the Company's signature/logo/emblem on social media. If we do not have such authority, we should state that we are employees of the Company when writing a post, and that the opinions expressed are our own statements, not the Company’s.

We must not disclose confidential or proprietary information on social media (or otherwise), including the Company's trade secrets, intellectual property rights, and copyrighted or trademarked information. While sharing information shared by persons authorised by the Company, we cannot change the content or form of the post.

We must be courteous, respectful, and make ethical decisions in our online statements. Under no circumstances should we make any defamatory, discriminatory, harassing, or retaliatory posts.

Whenever we have questions regarding online submissions, we should contact our team leader, Human Resources Department or Legal Consultant/Adviser for assistance.

10.4. Information Security Applications

Employees are obliged to comply with Information Security Practices at all times.

10.5. Other

Our commitment to ethical and honest behaviour requires us to be a party to legitimate and authorised business transactions. We can never make false claims, verbally or in writing, on behalf of the company.

11.A Conflict OF INTEREST

What Is a Conflict of Interest?

A conflict of interest arises from potentially challenging our ability to make objective decisions for company interests when personal interests conflict with, or appear to contradict, Company interests. Avoiding genuine conflicts of interest and situations that appear to be conflicts of interest enables us to gain and maintain the trust of our customers and other business partners, colleagues, and the public. Therefore, we must take care of this. The Company expects the employee to notify the Manager immediately in the event of a potential conflict of interest.

It is the responsibility of each of us to act in the best interest of the company and avoid actual, potential, or perceived conflicts of interest while managing company business.

11.1. Relations Between Employees

Conflict of interest mostly arises when there is a personal relationship between employees. While these relationships do not inappropriately influence the objective and sound business decisions, they can potentially have such an impact. This is especially true in romantic relationships or when we are in direct or indirect reporting relationships with family members. In addition, we cannot do paid or unpaid work for the person we report directly or indirectly, except for our job at the Company.

If we have a personal relationship that seems to affect our ability to make decisions, we must immediately notify our manager or supervisor, the Human Resources Department or Legal Consultant/Adviser.

11.2. Getting Personal Profit From Corporate Opportunities

We cannot direct a third party to pursue any opportunity we learn in connection with our employment or as a result of the use of company property or information, without written approval from the company's Legal Consultant/Adviser.

Company employees cannot use Company facilities to carry out their private business.

11.3. Conducting Business With Family Members While Working for the Company

We must be careful if one of our family members works for a company that the Company does business with or for which the company intends to do business. If we find ourselves in such a situation and our job requires us to make business decisions related to this company, before carrying out such transactions, we need to inform our department manager and/or Legal Consultant/Adviser and obtain written approval.

11.4. Investing Outside of the Company While Working for the Company

A conflict of interest may arise if we or any of our family members have a financial interest in any undertaking with which the Company does business or competes. The conflict of interest that may arise in this situation usually depends on the size of our investment, our role in the Company, and the business relationship between the Company and the other company. Before making such an investment or when we learn that such a situation has arisen, we need to obtain written approval from the General Manager.

11.5. Working Outside While Working for The Company

We must ensure that our interests and activities outside of duty do not conflict with our responsibilities in the Company. We cannot work outside without prior written approval from the Legal Consultant/Adviser and/or the General Manager. Regulatory clauses may be added to the service agreements concluded between the Company and the employee in relation to recruitment, employment as a consultant or not being a member of any organisation by a competitor, customer, or supplier of the Company, to be applied after their departure.

11.6. Doing Business with the Company After Termination of Employment

This is defined as doing business with the Company after the termination of the employment contract, establishing a company with the Company personally, holding a share in a company, entering into a contractual commitment, obtaining a representative office, opening a dealership, or doing similar commercial activities. This application cannot be done without written approval from the Legal Adviser/Consultant and/or the General Manager.

12. ANTI-CORRUPTION

No matter who we are working with, be it a public institution/organisation or commercial customer, bribery is never allowed in the Company. For this reason, we must never engage in bribery and must follow all anti-corruption laws and regulations, including the laws of the countries where we work.

This means:

No direct or indirect bribes, kickbacks, tips, or other improper payments can be offered, authorised, promised, or given to the officials of public institutions/organisations to influence their decisions or to ensure the realisation of a certain result or action.

No direct or indirect bribes, kickbacks, tips, or other improper payments are offered, authorised, promised, or given to business customers to do or continue business.

Direct or indirect bribes, kickbacks, tips, or other payments in connection with the Company cannot be demanded or accepted.

These rules apply in all conditions and circumstances, even if such payments are in line with local customary practices. At the same time, we must avoid any action that could create the impression of improperly affecting a government agency/organisation official or business customer. In case of a similar request, we must immediately inform the General Manager.

Any gift, treat or travel intended to be given to public institution/organisation officials must be approved in advance by the Company's General Manager and/or Chairman of the Board of Directors.

We must exercise due care when allowing third parties to act on our behalf. We should never work with third parties who would violate the Regulation, our Company policy or applicable laws and regulations.

13. VIOLATION OF ETHICS AND BEHAVIOUR POLICY

We must take the principles of this Policy seriously and always endeavour to follow them diligently. We should be aware that any violation of international and/or local laws, Company policies, regulations, guidelines, or this policy may result in the termination of the employee's service contract/employment contract.

In addition, we should be aware of the possibility of legal or criminal consequences for the infringers and the Company.

Within the scope of this Policy, the following communication channels can be contacted for notification:

Headquarters

Human Resources Department

13.1. Authority to Investigate Ethics Violations

The Ethics Violation Investigation Team has the responsibility of investigating all complaints and notifications of violations of the Company's Ethical Principles and related policies. The Ethics Violation Investigation Team reports the violation directly to the General Manager. The appointment of the Ethics Violation Investigation Team is made by the General Manager.

13.2. Principles of Investigation of Ethics Violation

Ethics violation investigation is conducted within the framework of the following principles:

  • Complaints/notifications and the identity of the complainant are kept confidential.
  • The investigation is conducted as confidentially as possible.
  • At the end of the investigation, all necessary measures are taken to protect the personal rights of the employee who is under investigation due to the possibility that the complaint is unfounded.
  • Information, documents, and evidence regarding the investigation can be requested directly from the relevant Department.
  • All information and documents can be analysed within the limits of investigation.
  • Investigation processes are recorded in writing. Information, evidence, and documents are added to the records.
  • The investigation is handled urgently and resolved as quickly as possible.
  • Recommendations made at the end of the ethical review are implemented quickly.
  • Relevant departments and officials are informed of the result.
  • A member of the Ethics Violation Investigation Team acts independently without being affected by the organisational hierarchy while performing their duties. There is no pressure or suggestion in this regard.
  • If 'Expert opinion' is deemed necessary by the Ethics Violation Investigation Team member, experts may be consulted to ensure that confidentiality principles are not violated during the investigation and that necessary measures are taken.

13.3. ZERO TOLERANCE FOR VIOLATIONS OF THE RULES

The Company adopts a zero-tolerance approach to violations of the Code of Ethics, failure to report the policy violation correctly, or retaliation against those who report. The Company may impose internal disciplinary provisions on employees who violate these rules or retaliate against those who report.

14. ENFORCEMENT

This Policy was accepted and entered into force on 10/07/2020.

 1. PURPOSE and SCOPE

 1.1. PURPOSE

The objective of this Anti-Bribery and Corruption Policy ('Policy') is a clear indication of our approach to bribery and corruption as QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş. ) ('Company' unless otherwise specified).

As a Company, we aim to comply with laws and regulations against bribery and corruption, with international and legal regulations, and with ethical principles in the country in which we operate, and to determine the responsibilities and rules in this regard.

In this context, the objective of this policy is;

  • To define principles and rules for detecting and preventing possible acts of bribery and corruption to protect the integrity and reputation of the company.
  • To provide information to all our employees on how to identify, reduce, and manage the risks of bribery and corruption.

1.2. SCOPE

As a Company, we expect all our employees and business partners to act in accordance with our Human Rights Policy. This Anti-Bribery and Corruption Policy covers our basic principles regarding the scope of combating corruption.

Persons/organisations for which the Anti-Bribery and Corruption Policy shall apply include:

  • Company managers and employees.
  • Respective affiliates, jointly controlled entities and their employees.
  • Third parties we receive service from, contractors, agents and similar persons, and organisations acting on behalf of or together with the Company including contractors, consultants, lawyers, external auditors.

This Anti-Bribery and Corruption Policy is approved by the General Manager and is a part and parcel of the Human Rights Policy, Ethics and Behaviour Policy, Disciplinary Regulations, Occupational Health and Safety and Staff Manual, Quality Management System Policies, Human Resources Procedures and other regulations, instructions, and/or policies.

At the beginning of the employment relationship with our employees and business partners, these above-mentioned policies, procedures, and regulations etc. are shared promptly. In addition to this, the relevant documents are placed and made available to the public on our corporate web page.

2. DEFINITIONS

The special terms and phrases, concepts, and abbreviations mentioned in this Anti-Bribery and Corruption Policy are briefly described.

Company: QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş)

Management Team: QTerminals Antalya Department Managers/Directors/Employees

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

Public Official:  Includes people who participate in the conduct of public activities on a permanent, periodic, or temporary basis by appointment or election under any circumstances. 'Public', means all organs of the state that provide public service.

Corruption:  The abuse of the authority occupying the current position for the purpose of making any kind of profit, directly or indirectly. Corruption includes embezzlement, abuse of trust, and other financial misconduct but is not limited to the following:

  • Forgery or fraud of any documents and accounts belonging to the Company.
  • Forgery of fraud of any check, bank note, or other financial document.
  • Irregularity in the use of any funds, shares, and/or other assets of the Company.
  • Non-compliance with the execution or reporting of cash or financial transactions.
  • Profit from confidential information about Company activities.
  • Intentional misrepresentation in all kinds of transactions, events, and important information contained in financial reports.
  • Intentionally complex transactions designed to misrepresent the Company's financial performance.
  • Intentional abuse of accounting principles in terms of quantity, classification, presentation, and disclosure.
  • So as to allay any suspicion, it should be noted that the act of corruption also includes bribery.

Bribery: Acting contrary to the requirements of his/her duty or providing an advantage to another person by doing, not doing, accelerating, slowing down a job related to the performance of duty; obtaining, offering, or promising benefits directly or through intermediaries; requesting or accepting such; soliciting such, etc.

Bribery and corruption can take many forms, including the following:

  • Cash payments.
  • Political or other donations.
  • Commission.
  • Social rights.
  • Gift, reception.
  • Other interests.

3. RESPONSIBILITIES

3.1. General Manager

Is responsible for the approval of the Anti-Bribery and Corruption Policy and for the determination and operation of the notification, review, and sanctions mechanisms in the event of non-compliance with rules and regulations. They perform their duties within the framework of the powers granted by the Board of Directors.

3.2. Audit Committee

The Anti-Bribery and Corruption Policy Audit Committee consists of officials determined by the written approved of the General Manager.

The duties and responsibilities of the Audit Committee are converted into written form in accordance with the relevant legal regulations, approved by the General Manager, and declared to the public on our website. The Audit Committee is responsible for:

  • Assisting the Board of Directors in carrying out audit and supervision activities.
  • Monitoring the operation and effectiveness of the internal control system with an accounting and reporting system.
  • Conducting a risk assessment of firms providing support services and monitoring the competency of these firms and conducting an audit if necessary.

The Audit Committee has been given the task and authority to make an independent assessment about competence of the systems and/or policies of Anti-Bribery Policy.

3.3. Management Team

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

It is the responsibility of the management team to put into effect and control the practices related to the Anti-Bribery and Corruption Policy. It is also responsible for taking the necessary measures to ensure the compliance of employees and external service firms with this policy and notifying the General Manager for the purpose of examining issues contrary to this policy.

The Management Team consists of Department Managers and Executives.

3.4. Legal Adviser/Consultant

The Company's Legal Adviser/Consultant evaluates the Anti-Bribery and Corruption Policy in terms of currency and development needs when necessary and may make recommendations to the Management Team.

3.5. Employees and Managers

  • All employees and managers accept the Anti-Bribery and Corruption Policy and act in accordance with the principles, relevant laws and regulations, and all applicable anti-corruption rules in the policy text.
  • Employees are responsible for abiding and complying with Company policies, regulations, and procedures and working in compliance with current legislations.
  • All employees are responsible for notifying the points of contact specified in the POINTS OF CONTACT section or the Anti-Bribery and Corruption Notification E-mail line in the event of of non-policy behaviour, activity, or practice.
  • Employees cannot be forced to act in violation of this policy under any circumstances by anyone. Employees who do not give bribes are not retaliated against or penalised.
  • Managers ensure that the principles in the policy text are understood, implemented, and maintained by the business partners for whom they are responsible and the employees under their supervision.
  • Managers are obliged to report complaints, notices, and claims received by employees under their supervision to the points of contact in the POINTS OF CONTACT section.

 3.6. Ensuring Agreement With the Selection of External Service Companies and Business Partners

External Service Companies and Business Partners must comply with the principles of the Anti-Bribery and Corruption Policy and other relevant regulations, and work with individuals and organisations that do not comply with these shall be terminated.

At the selection stage of companies and business partners who buy and sell goods and services, criteria such as experience, financial performance, and technical competency as well as their level of ethics and positive background in the field are also taken into account. Firms or business partners with negative intelligence regarding bribery or corruption shall not be workable, even if they meet other criteria. In this context, the responsibility of conducting the necessary research and evaluations before developing any business relationship lies primarily with the General Manager.

3.7. 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.

3.8. Human Resources Department

For the purpose of compliance with this policy, the Human Resources Department is responsible for taking the necessary measures during human resources processes (recruitment, communication, training etc.) and for distributing this policy internally.

4. OUR ANTI-CORRUPTION AND BRIBERY PROGRAM AND COMMITMENTS

As a Company, in every field and area, we comply with national laws and regulations on bribery and corruption, universal rules of law, and ethical and professional principles, especially the OECD Anti-Bribery Convention.

Within the framework of the Anti-Bribery and Corruption Policy, we carry out activities aimed at fulfilling the following issues and undertake to take the necessary measures.

4.1. Receiving or Giving Bribes

  • The Company opposes all forms of bribery and corruption and is committed to compliance with applicable laws, regulations, and principles. Receiving or giving bribes, regardless of the purpose, is strictly prohibited.

Zero Tolerance

  • As a Company, we act with a 'ZERO TOLERANCE' approach to bribery and corruption in accordance with this principle and are committed to maintaining our activities in a fair, honest, transparent, legal, and ethical manner. This Anti-Bribery and Corruption Policy is also implemented as a requirement of the importance given to this issue.
  • We expect our employees to show sensitivity in this regard and treat this as a part of their personal assignments and responsibilities regardless of working life, due to the fact that the subject is an illegal act in addition to a violation of business ethics.

4.2. Facilitation Payments

  • The company prohibits any payment to be made to facilitate and expedite business.
  • Company employees do not tolerate their correspondents offering, promising, soliciting, giving or accepting bribes in their dealings with third parties.

4.3. Representatives, Suppliers, Customers, Agents, and Business Partnerships

  • A business relationship is developed with representatives, agents, suppliers, customers, contractors, and business partnerships that are believed to protect the Company's reputation and work in accordance with the company's Anti-Bribery and Corruption Policy.
  • Any benefit from suppliers, agents, dealers, authorised services, and customers should not be accepted if offered.
  • The Company does not deal with persons or companies on blacklists created in accordance with the information received from public authorities, international data providers, and social media sources to ensure compliance with current regulations and the Company's own rules. The Company creates and explains a blacklist of whom not to deal with.

4.4. Gifts and Receptions

  • In conducting relations with private or public persons and organisations that want to establish or maintain a business relationship with the Company, apart from generally accepted promotional materials, any gift or reception that creates the impression of the existence of an irregularity or that can cause or could be perceived as dependency cannot be received or offered.

4.5. Relations With Public Institutions

  • Unless the necessary approvals are given (gifts, entertainment, etc.), it is not permitted to offer, promise, or give gifts, receptions, or any other benefits directly or indirectly to the employees of a foreign or domestic public institution.
  • In addition, our employees cannot directly or indirectly bribe public officials to ensure their interests in public affairs. For this reason, our employees are obliged to act in accordance with our Company's Anti-Bribery and Corruption Policy.

4.6. Recruitment Process:

  • In order for any job offer made by the Company to not give the impression of bribery and corruption, it must be carried out within the competitive recruitment process established by the Company's procedures.

4.7. Donations, Charities and Sponsorships:

  • No donation for political purposes can be made on behalf of the Company. In cases where it is determined that donations/political donations have been made in violation of policy during the compliance audit, internal audit, or independent audit, this situation is declared to the public.
  • Charitable contributions and sponsorships to be made by the Company must be legal and comply with the company's regulations, policies, and directives, and also comply with current local laws.

 5. Keeping Records

  • The issues that our affiliates must comply with regarding the accounting system are regulated within the framework of the relevant legislation and regulations.
  • We take care that all kinds of accounts, invoices, and documents belonging to transactions are kept in a complete, transparent, accurate, fair, and reliable recording manner.
  • That internal control systems to prevent unrecorded transactions are established.
  • And that no changes are made to accounting or similar commercial records related to any transaction and that the facts are not deflected.

6. Training and Communication

All employees of the Company and contractors, suppliers, agents, and business partners are informed about anti-bribery and corruption issues, and the relevant parties are trained to assimilate the principles contained in this policy.

A training and awareness-raising program is provided to employees and business partners about the legal requirements related to the anti-bribery and corruption program.

Secure and accessible communication channels are provided where employees can report suspicious activity.

7. NOTICE OF VIOLATIONS OF BRIBERY AND CORRUPTION

To protect the reputation of our Company, it is the responsibility of everyone mentioned above to report any situation related to violations of the anti-bribery and corruption rules.

Failing to report acts of bribery and corruption to the relevant authorities or ignoring them will also be considered violation of the rules against bribery and corruption if detected.

Our confidential and anonymous communication channel, which has been created to address questions about the Anti-Bribery and Corruption Policy and those who violate the rules set out in this policy, or suspicious activity that may damage our reputation and trust, is described below:

Anti-Bribery and Corruption E-mail Notification Line: is etik@QTerminals-Antalya.com In addition, the communication channels contained in the points of contact section of this policy can also be contacted.

In cases where notifications are not made anonymously, it is the responsibility of the General Manager to keep the information of the notifying people confidential and to take the necessary measures to ensure that they are not exposed to any negative situations in relation to the notification. No retaliation shall be made against the employee who notifies.

7.1. VIOLATION OF ANTI-BRIBERY AND CORRUPTION RULES AND CONSEQUENCES

All our employees and all business partners mentioned above are required to know the rules contained in this policy and to comply with these rules and the current anti-bribery and corruption legislation in the conduct of their business.

Ignorance of the rules contained in this policy shall not be considered as an excuse for violation.

In case of violation of this policy, non-judicial punishment that may lead to termination of the employment contract shall be applied depending on the nature of the incident.

In addition, those who do not comply with the relevant legal regulations and all current anti-corruption laws may be subject to criminal liability.

Employees or business partners shall not be exposed to any negative situations as a result of refusing to participate in a bribery and corruption incident or reporting a bribe or corruption. In such cases, it is necessary to contact the communication channels specified in this policy.

8. MONITORING, AUDIT, AND IMPROVEMENT PROCESS

This Anti-Bribery and Corruption Policy is periodically reviewed by the Management Team, and practices are regularly monitored and evaluated ands reported to the General Manager annually. Inclusion of bribery and corruption issues in general risk-based assessment processes and regular risk assessment in this field with annual controls are applied to eliminate corruption risks.

The Management Team regularly reports to the General Manager about the effectiveness of the anti-corruption program.

9. Policy Violations

In cases where there are or may likely be likely violations of the policy, the issue is examined by the Management Team and reported to the General Manager for the implementation of the necessary sanctions if misconduct is detected.

10. Support and Protection of Personnel Acting in Accordance with the Policy

The Company states that personnel who follow the rules on the prevention of bribery and corruption shall not be harmed in any way due to complying with these rules, that it shall protect him/her under any situation and circumstance, and that any notifications to the relevant parties shall be kept confidential.

 11. VALIDITY

This policy is adopted and entered into force with the approval of the General Manager on 10/07/2020.

11.1. POINTS OF CONTACT

Human Resources Department: ik@QTerminals-Antalya.com

Anti-Bribery and Corruption E-Mail Notification Line: etik@QTerminals-Antalya.com


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