In light of its mission, vision, values, and strategic goals and within the framework of the management principle, QTerminals Antalya has adopted the principle of increasing profitability and efficiency.
In the light of the mission, vision, values, and strategic goals it has determined and within the framework of the management principle, QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) has adopted as its basic principle to increase profitability and efficiency, to keep customer satisfaction at the highest level by providing quality service to its customers, and to ensure the continuity of all these principles.
Within the scope of the Quality Management System and Customer Satisfaction Management System, which it established to strengthen its position in the port sector in line with national and international norms and which were given TS EN ISO 9001:2015 and ISO 10002:2006 certification respectively by the TSE
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
QTerminals Antalya has adopted the following Health and Safety Policy as a principle, in line with the work it carries out in accordance with ISO 45001 Occupational Health and Safety Management System standards. Health and safety are of paramount importance among all other activities, and efforts are made to carry out the safest operations, on land or at sea, by complying with the rules introduced by legislation.
QTerminals Antalya management acts with the awareness that providing a safe working environment for third parties using the port by sea and land and reducing unnecessary losses and liabilities that may occur are among its primary objectives. QTerminals Antalya Management is looking for ways to avoid work-related health problems and accidents. To this end, it has developed a Health and Safety Management System. The important point here is to determine the health and safety risks and to explain these risks to employees and third parties using the port as clearly as possible and take precautions.
QTerminals Antalya Management acknowledges that employees are the most important resource/factor in the fulfillment of Health and Safety Policies. It acts with the awareness of an organizational structure and responsibility that has continuity in terms of creating a healthy and safe working environment culture for its employees.
QTerminals Antalya General Manager is the highest authorized person when it comes to the purpose and implementation of Health and Safety Policies. Other department managers report to the General Manager and are responsible for monitoring the fulfillment of Health and Safety Policies, implementing them in the workplace, keeping records when necessary, and reporting periodically.
In the implementation of these rules, management must ensure:
QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) management has generated and runs its Information Security Management System to fulfill the requirements stated in ISO/IEC 27001 to actualize the objectives and policies it stipulates in ISO 27001. In this context, all assets containing information are managed in line with the principle of 'confidentiality, integrity, and accessibility.
As a result of this undertaking, it organizes information security awareness programs throughout the Company and continues to invest in infrastructure.
The ISMS Management Representative is appointed by the senior management in writing when the ISMS is established. When the ISMS Management Representative changes or leaves the job, the document is revised by the senior management, and the assignment is made again.
Managers at the management levels help the personnel at lower levels in matters of security by giving responsibility and setting an example. With an understanding of security that starts and is applied from the top down, it is imperative to go down to the lowest level personnel of the Company. For this reason, the managers in the Company support those personnel who are working on security to comply with the security procedures, both in writing and verbally, and participate in security studies.
All relevant legislation requirements that the business is responsible for complying with within the scope of Information Security Management are provided and made permanent.
QTerminals Antalya senior management creates the budget needed for comprehensive information security studies.
Access controls in QTerminals Antalya are carried out in accordance with the 'Everything is Forbidden Unless Explicitly Allowed' rule instead of the understanding of 'Everything is Allowed Unless Explicitly Prohibited', and this rule is adopted by all users.
Access control principles within the enterprise are defined as: 'Need to know: you are only given access to the information you need to perform your tasks' and 'For use: you are only given access to the information processing facilities required to perform your tasks/job/role'.
QTerminals Antalya management undertakes to comply with the Information Security Management System that has been defined, put into effect, and is being implemented, and to allocate the resources necessary for the efficient operation of the system, to continuously improve its effectiveness, and to ensure that this is understood by all employees.
QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) has adopted the principle and goal of carrying out the handling and/or storage of hazardous material by keeping the safety and security of life, property, and the environment at the highest level.
In this context, the priority and ongoing hazardous materials accident prevention policy of QTerminals Antalya
It is our policy to provide effective and continuous protection to the maximum extent to prevent accidents such as death, injury, material damage, and environmental pollution, which hazardous materials may cause or be involved in, and minimize their damage to people and the environment.
This Policy includes the principles of QTerminals Antalya's (Ortadoğu Antalya Liman İşletmeleri A.Ş.) Personal Data Retention and Disposal (PDRD Policy).
It is strictly forbidden to copy, reproduce, use, publish, distribute, or put on the commercial market through plagiarism any text, photograph, or other content in a book, in whole or in part, without written permission or approval, except for individual use within the scope of Intellectual and Artistic Works Law (Copyright Law) No. 5846.
Legal action will be taken against those who do not comply with this prohibition in accordance with Copyright Law No. 5846. All rights of the product are reserved.
BASIS, PURPOSE, AND SCOPE
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.
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.
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,
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,
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
The deletion, destruction, or anonymisation of personal data processed by QTerminals Antalya and for which all processing conditions no longer exist, in other words, the disposal of personal data, is carried out with the processes and methods explained below in accordance with the standards and legislation stated in this Personal Data Protection Policy.
a. Disposal of Data Processed Before the PDP Law
Pursuant to Provisional Article 1/3.f of the PDP Law, the personal data previously processed by QTerminals Antalya was brought into compliance with the provisions of the PDP Law and the standards of the PDP Policy within two years of the date of publication of the Law.
Regarding personal data that was previously processed but for which explicit consent was not obtained or personal data received without the need for explicit consent under Articles 5 and 6 of the PDP Law, QTERMINALS ANTALYA has reached out to the data subjects and obtained their explicit consent including a disclosure text in line with relevant legislation and the provisions and conditions of the PDP Policy. Personal data that was previously processed but where the subject of which could not be reached or their explicit consent could not be obtained and personal data that was processed without any legal requirement for explicit consent, are deleted, destroyed, or anonymised either ex officio by QTerminals Antalya or at the request of the data subject due to the reasons for processing no longer existing as per Article 7 of the PDP Law.
On the other hand, the consents obtained by QTerminals Antalya in accordance with the law before the publication date of the PDP Law are considered to be in accordance with the legislation and the terms of the PDP Policy, unless a statement of intent to the contrary is made within one year.
b. Disposal of Data Processed After the PDP Law
QTerminals Antalya deletes, destroys, or anonymizes the personal data it has processed ex officio or at the request of the person concerned, in accordance with the standards of this Personal Data Protection Policy, in the event that all the conditions for processing personal data referred to in the PDP Policy and Articles 5 and 6 of the PDP Law no longer exist.
Within the scope of the PDRD Policy, QTerminals Antalya acts in accordance with the general principles in Article 4 of the PDP Law and the provisions of the PDP Policy, and the technical and administrative measures that need to be taken within the scope of Article 12 of the PDP Law and again this PDP Policy, relevant legislation, and the decisions of the PDP Board when it deletes, destroys, or anonymises the personal data it has processed.
In this context, all transactions relating to the deletion, destruction, and anonymisation of personal data are recorded and the said records are kept for at least three years, excluding other legal obligations. 'In this context, all transactions related to the deletion, destruction, and anonymization of personal data are recorded and the said records are kept for at least three years, excluding other legal obligations'.
(4) The data controller is obliged to explain in the relevant policies and procedures the methods applied for the deletion, destruction, and anonymisation of personal data.
(5) Unless otherwise decided by the Board, we select the appropriate method of deleting, destroying, or anonymising personal data. At the request of the data subject, he/she chooses the appropriate method by explaining the reason for this choice.
Personal Data Disposal Process
Regarding the disposal of personal data, the processes that QTerminals Antalya should follow in its processes and activities are respectively:
Deletion of Personal Data
Deletion of personal data is the term given to the processes and activities of making personal data inaccessible and non-reusable for the relevant users.
As the data controller, QTerminals Antalya takes all necessary technical and administrative measures to ensure that the deleted personal data cannot be accessed and reused by the users within the scope of this Policy and the PDP Law.
Methods of Deleting Personal Data
Personal data processed by QTerminals Antalya can be recorded and stored in more than one medium. For this reason, data are deleted by means and methods suitable for the characteristics of the recording medium in which they are stored. The deletion methods applied by QTerminals Antalya are listed below, in order.
i. Deletion of Personal Data in the Cloud
After determining the personal data subject to deletion regarding the data stored as digital media in the cloud (Office 365, Google Drive, OneDrive, Salesforce, etc.) performed as a service procurement by QTerminals Antalya, an evaluation is made in terms of each personal data, and the authorization to access this data is removed using administration panels, a control matrix, or similar electronic systems, the users of these data and these users' authorizations and methods such as data access, retrieval, and reuse are identified, then these data and the usage rights for them are deleted, closed, and removed using the delete command.
While performing these operations, it is determined whether or not the relevant user has the authority to restore the deleted data on the cloud system, and if he has such authority, this authority is removed or closed.
ii. Deletion of Personal Data in Paper Media
Personal data can also be physically processed and stored by QTerminals Antalya on paper. Deletion of such personal data stored in paper media is made by QTERMINALS ANTALYA by obfuscating them, apart from this method, the paper containing these data is cut, shredded, and destroyed so that it cannot be reversed, used, or read using shredders positioned in sufficient numbers in work areas where QTerminals Antalya operates.
iii. Deleting the File Located on the Central Server (Server)
Personal data is also contained in the files and the contents kept by QTerminals Antalya on the central server or servers.
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:
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.
In accordance with PDPL ( Personal Data Protection Law) No. 6698, which entered into force on 07.04.2016, QTerminals Antalya, its customers, employees, as well as personal data processed during its relations with natural or legal persons with whom they communicate and interact, should be connected to a legal order due to the obligations and requirements imposed by the legislation.
QTerminals Antalya pays high attention and attention to the principles of personal data security and privacy of its customers, staff, and related persons with whom it communicates and interacts. In this context, the personal data security of the persons concerned is given priority during the performance of the services.
Any personal data (including personal data of special nature) that may be related to a natural person in accordance with the provisions of the above-mentioned law is considered personal data in accordance with the PDP law. This personal data is processed by QTerminals Antalya as a data officer by the methods described below and within the limits ordered by the legislation.
“The processing of personal data” the data completely or partially automated, or any data recording system to be part of the record with non-automatic ways of obtaining, recording, storage, preservation, modification, rearrangement, disclosure, transfer, acquisition, can be obtained, making the use classification or refers to any operation that is performed on the data such as the Prevention of.
Purpose And Legal Basis For Processing Personal Data
Personal data may be collected electronically or physically by QTerminals Antalya in written or oral form, including voice and video recording, via platform registration, telephone, fax, e-mail, SMS and other social media, mobile applications, by automatic or non-automatic methods in accordance with the legislation.
No. 6698 PDPL nun 5. in the framework of the article
Sharing and transfer of personal data
Personal data of the relevant person; the legislation deems mandatory where requested by official institutions, as part of the activities and responsibilities of the Mediterranean, port, commercial, legal and economic relationship with domestic/foreign partners, project partners, cooperation partners, and program supply provider institutions, and the independent auditor organizations, banks and financial institutions other companies that have received help and support people and organizations, lawyer, financial advisor, law, Informatics, it can be shared with consulting firms such as quality and financial consultants by taking the necessary electronic and physical security measures by QTerminals Antalya Transferable. This also applies to sharing and transfer transactions abroad.
QTerminals Antalya the personal data of the person concerned, subject to appropriate security measures, primarily in Turkey or the EU countries, USA, UK, including other countries located abroad, storage, archiving, received the support of Information Technology, servers, hosting companies, program, cloud computing, etc, you can transfer to other electronic media, process it, and you can store it.
Method Of Collecting Personal Data
Personal data of the relevant person; approval and/or acceptance signed by all agreements/disclosure forms and miscellaneous documents, electronic confirmation and/or performed with a signature, ratification, acceptance, and notifications, the administrative center of the Mediterranean port, physical environments, call centers, websites, mobile applications, Internet Operations, social media, and other public areas, user interviews, judicial records scanning, market research, identity sharing system, SMS, internet sites, digital applications, mobile applications, sales teams, written/digital references, contacted with the contact or call center that may contact in the future with methods such as oral, written, video, audio recording or electronic media data obtained in fully or partially automated, or any data recording system as part of the period of limitation in accordance with relevant legislation are collected and are kept in consideration.
Personal data collected by QTerminals Antalya for the above-mentioned legal reasons 5 of the law on the protection of personal data No. 6698. and 6. it may also be processed or transferred for the purposes described earlier in this policy, taking into account the personal data processing conditions specified in its articles.
User Rights (11 of the PDP Law No. 6698. according to the article)
Related persons, with respect to their personal data, QTerminals Antalya’s personal data via the following email address;
Data Officer Who Can Apply Under The Law
QTerminals Antalya Data Officer www.kvkk.gov.tr he is the person whose address is registered in the VERBIS system.
In accordance with the above-mentioned rights, the person concerned may send their requests, complaints, suggestions to the following address of QTerminals Antalya by applying in person or through a notary or by specifying the e-mail address reported by the user at the time of opening the account and registered on the website to the e-mail address mentioned below.
First name, last name, t.C. identification number, settlement or workplace address based on notification, mobile phone number, e-mail address and the subject of the request must be found, information and documents related to the request must also be added to the application
In correspondence with QTerminals Antalya, the official language is Turkish. For this reason, it is essential that all kinds of applications, correspondence, problems, complaints and suggestions are written and sent in Turkish.
If the application is sent in writing and physically, the signature must be wet signed.
Answers to requests, problems, suggestions, and complaints are generally not subject to fees. However, if there are costs, fees, or other costs associated with the response, QTerminals Antalya reserves the right to charge fees in accordance with the PDPL regulations or in the tariff set by other authorities.
For more detailed information or for your problems, requests, suggestions, and complaints about PDP policy 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.
Liman Mah. Liman Cad. No:43/6 Konyaaltı / Antalya
1. PURPOSE and SCOPE
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.
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.
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:
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.
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.
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.
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.
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.
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:
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.
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
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;
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.
This Policy covers the managers and employees of QTerminals Antalya (Ortadoğu Antalya Liman İşletmeleri A.Ş.) at all levels.
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.
3.1. 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.
3.4 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:
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 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:
Some Examples of Misconduct
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.
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.
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:
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
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:
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
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
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.
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.
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.
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.
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:
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:
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.
This Policy was accepted and entered into force on 10/07/2020.
1. PURPOSE and SCOPE
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;
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:
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.
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:
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:
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:
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
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
4.2. Facilitation Payments
4.3. Representatives, Suppliers, Customers, Agents, and Business Partnerships
4.4. Gifts and Receptions
4.5. Relations With Public Institutions
4.6. Recruitment Process:
4.7. Donations, Charities and Sponsorships:
5. Keeping Records
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.
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