OUR WORKING ETHICS
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BUSINESS ETHICS PROCEDURE – INVESTIGATION AND PREVENTION OF UNETHICAL BEHAVIORS

Purpose

The purpose of this procedure is to explain the ethical principles that employees of AKINAL AYAKKABICILIK SANAYİ VE TİC. A.Ş. must adopt.

Introduction

As managers and employees of AKINAL AYAKKABICILIK SANAYİ VE TİC. A.Ş., we have a system of beliefs and values that guides how we perceive our work, the company, our colleagues, customers, suppliers, and other stakeholders. This system, referred to as our Business Ethics Rules, frames our relationships, decisions, and actions. These rules represent a standard of conduct for all employees and cannot be ignored or opposed. They guide both personal and corporate decisions while ensuring compliance with economic, social, legal, and environmental responsibilities. We acknowledge the importance of this document, commit to following these rules, and support their implementation across the company.

A. Confidentiality

Information Flow Rules:

  • Company Information

  • Prohibition of Information Trading

  • Information Systems

  • Confidentiality of Electronic or Other Information

  • Financial Information

  • Reporting

  • Media Inquiries and Interview Requests

All company information is confidential and may not be shared or traded with third parties. Employees must respect the confidentiality of company, client, and personal information and only use it for company purposes. Upon leaving the company, confidential information must not be disclosed or used for personal benefit or in another company.

B. Integrity

We prioritize truthfulness and honesty in all business processes and relationships. Employees must act with integrity in dealings with colleagues, stakeholders, and partners.

C. Conflict of Interest

Employees must avoid situations where personal interests conflict with the company’s. Company resources, identity, and power must never be used for personal gain, and all employees must avoid actions that could damage the company’s reputation.

D. Responsibilities

1. Legal Responsibilities:
All domestic and international operations comply with applicable laws and regulations.

2. Customer Responsibilities:
We aim for customer satisfaction, respond proactively, and act with respect, fairness, and courtesy.

3. Employee Responsibilities:
We ensure fair and safe working conditions, support personal development, and maintain a healthy work-life balance.

4. Supplier / Partner Responsibilities:
We maintain professional and transparent relationships without personal favors or inappropriate benefits.

5. Competitor Responsibilities:
We compete ethically and avoid unfair practices.

6. Responsibilities to Society and Humanity:
We support democracy, human rights, environmental protection, education, and social welfare activities.

7. Responsibilities to the Company:
Employees must protect the company’s reputation, comply with rules, and act ethically in all business matters.

Conflict of Interest Policy

  • Avoid transactions with family, friends, or related third parties.

  • Do not engage in paid work for competitors or related companies without board approval.

  • Do not use company assets, name, or power for personal gain.

  • Gifts, bribes, or commissions are strictly prohibited.

Employees may accept or give symbolic, culturally appropriate gifts if approved by management and compliant with applicable regulations.

Confidential Information Policy

Confidential information includes intellectual property, designs, technical information, personnel records, customer data, financial information, strategic plans, and any other company-related data.

  • Confidential information must not be disclosed without proper authorization.

  • Information must not be altered, copied, or destroyed improperly.

  • Access credentials are strictly confidential.

  • Confidential discussions are not permitted in public areas.

  • When sharing with third parties, confidentiality agreements must be signed.

Fair Workplace Policy

  • Comply with all employment laws and regulations.

  • HR policies ensure fairness in hiring, promotion, compensation, and rewards.

  • No discrimination based on gender, religion, race, political opinion, disability, etc.

  • Collaboration and a positive work environment are promoted.

  • Respect employees’ privacy, safety, and dignity.

Managers’ Responsibilities

  • Establish and maintain an ethical company culture.

  • Lead by example and train employees on ethics.

  • Support employees in reporting ethical concerns.

  • Ensure business processes minimize ethical risks.

  • Monitor adherence to policies and procedures.

Ethics Committee

  • Investigates complaints and ethical violations.

  • Maintains confidentiality of complainants.

  • Ensures impartial and thorough investigations.

  • Reports results to management and takes corrective actions.

Composition:

  • Chair: Senior Audit Officer

  • Member: Legal Counsel

  • Member: Senior HR Manager

Employee Declaration

"I have read the Business Ethics Procedure. I commit to comply with workplace ethics, serve in accordance with my company’s purpose, and protect its interests at all times."

Employee Signature: ___________

"I have re-read the Workplace Ethics Procedure and declare that I will act according to my company’s purpose and comply with the Ethics Procedure."