Quality Standards

Integrated Management Systems

Kalite Yönetim Sistemi Politikası

Kalite Yönetim Sistemi Politikası, Gediz Elektrik Perakende Satış A.Ş (“Şirket”) nin kalite yönetimine yaklaşımını göstermektedir. Şirket, ISO 9001 Kalite Yönetim Standardının gereklerine göre belirlediği kapsam ve hedefler çerçevesinde; süreç odaklı ve başarıyı hedefleyen müşteri deneyimini oluşturmayı, çalışanlarına kişisel gelişim ve kariyerlerini ilerletebilecekleri bir iş ortamını sağlamayı, müşterileri ile çalışanlarına kattığı değeri ve şirket karlılığını arttırmayı hedefler. Şirket, müşteri talep ve beklentilerini göz önünde bulundurarak hedeflediği kalite anlayışında sürekli gelişim sağlar.

Bu doğrultuda Kalite Yönetim Sistemi Politikamız;

Şirket faaliyetlerini ilgili tarafların talep ve beklentilerinin anlaşılması, müşteri memnuniyetinin sağlanması ve sürekli iyileştirilmesi amacıyla sürdürmek,
Bağlı olunan ulusal ve uluslararası standartlara ve tüm yasal mevzuatlar ile diğer gerekliliklere uyum sağlamak,
Tüm faaliyetlerimizde kalite yönetim sistemi koşullarını yerine getirmek ve sürekli iyileştirmek,
Kalite anlayışımız gereği Şirket ve birim hedeflerine ulaşılırken takım ruhu ile hareket etmek,
Düzenlenen eğitim programları ile çalışanların gelişimini sürekli desteklemek, çalışan memnuniyeti ve bağlılığını sağlamak,
Şirket faaliyetlerinde yenilikçi ve yaratıcı tutumları desteklemek,
Risk ve fırsatların değerlendirilmesi bakış açısı ile iş süreçlerini gözden geçirmek, şirket verimliliğini geliştirecek yaklaşımları uygulamak,
Tüm çalışanlarımızın kalite bilincini artırmak,

Politikamız müşterilerimize, çalışanlarımıza ve ilgili tüm taraflara her zaman açık ve ulaşılabilir olacaktır.

İş Sağlığı ve Güvenliği Yönetim Sistemi Politikası

İş Sağlığı ve Güvenliği Yönetim Sistemi Politikası, Gediz Elektrik Perakende Satış A.Ş (“Şirket”) nin iş sağlığı ve güvenliğine olan yaklaşımını göstermektedir. Şirket, ISO 45001 İş Sağlığı ve Güvenliği Yönetim Sistemi Standardının gereklerine göre belirlediği kapsam ve hedefler çerçevesinde, riskleri ortadan kaldırarak veya en aza indirerek, sağlıklı, güvenli bir çalışma ortamının oluşturulmasını hedefler ve oluşturduğu bu çalışma ortamındaki faaliyetlerin sürekli iyileştirme yaklaşımı ile ele alınacağını taahhüt eder.

Bu çerçevede İş Sağlığı ve Güvenliği Yönetim Sistemi Politikamız;

İş sağlığı ve güvenliği ile ilgili yasal düzenleme, mevzuat hükümleri ve standartlara uymak,
Şirket bünyesinde güvenli ve sağlıklı çalışma alışkanlığının içselleştirildiği bir kültürün oluşturulması için gerekli politika, prosedür ve sistemleri oluşturmak,
İş sağlığı ve güvenliğini olumsuz etkileyecek risklerin belirlenip, iş kazaları ve meslek hastalıklarının önlenmesi amacıyla gerekli önlemleri almak, tüm çalışanlarının, alt yüklenicilerinin ve ziyaretçilerinin sağlık, güvenlik ve sosyal refahlarını temin etmek,
Çalışanların iş sağlığı ve güvenliği farkındalığının oluşturulması ve geliştirilmesi için uygun eğitimlerin verilmesini sağlanmak,
İş sağlığı ve güvenliği konularında çalışanların görüş ve önerilerini alarak çalışan katılımını en üst düzeye çıkarmak ve sağlık ve güvenlik konularında her türlü bilgiyi çalışanlarla paylaşmak,
İş sağlığı ve güvenliği performansını artırmak, denetlemek ve sürekli iyileştirilmesini sağlamak,
Kurmuş olduğumuz İş Sağlığı ve Güvenliği Yönetim Sisteminin sürekliliğini sağlamayı taahhüt eder.

Politikamız müşterilerimize, çalışanlarımıza ve ilgili tüm taraflara her zaman açık ve ulaşılabilir olacaktır.

Çevre Yönetim Sistemi Politikası

Çevre Yönetim Sistemi Politikası, Gediz Elektrik Perakende Satış A.Ş (“Şirket”) nin çevreye olan yaklaşımını göstermektedir. Şirket, ISO 14001 Çevre Yönetim Sistemi Standardının gereklerine göre belirlediği kapsam ve hedefler çerçevesinde; faaliyetlerinden dolayı meydana gelebilecek olumsuz çevresel etkileri minimize etmeyi ve çevrenin korunmasına katkıda bulunabilmeyi hedefler. Şirket; hedeflediği çevrenin korunması anlayışını sürekli iyileştirmeyi taahhüt eder.

Bu çerçevede Çevre Yönetim Sistemi Politikamız;

Bu çerçevede Çevre Yönetim Sistemi Pol-Çevre ile ilgili yasal düzenleme, mevzuat hükümleri ve sözleşmelere uymak,

Süreçlerinde yenilenebilir enerji kaynakları kullanımını artırmak, çevre dostu ve enerji verimliliğini önemseyen ürün ve hizmetleri tercih etmek,
İş süreçlerinin çevre yönetim sistemi kapsamında yayınlanan politika ve prosedürlere uygun şekilde yürütülmesini sağlamak,
Sürdürülebilir kalkınma bakış açısıyla çevrenin korunmasına, kirliliğin önlenmesine özen göstermek ve atıkların kaynağında azaltılmasını sağlayarak geri kazanım yöntemlerimizi geliştirmek,
Şirket bünyesinde çevre farkındalığının artırılması ve çalışanların yetkinliklerinin geliştirilmesi amacı ile eğitimler gerçekleştirmek,
Çevre Yönetim Sisteminin kurulması, işletilmesi, performansının artırılması, sürekli iyileştirilmesi ve bunlar için ihtiyaç duyulan insan, altyapı, teknoloji ve finansal kaynakları sağlanmayı taahhüt eder.

Politikamız müşterilerimize, çalışanlarımıza ve ilgili tüm taraflara her zaman açık ve ulaşılabilir olacaktır.

Business Continuity Management System Policy

The Business Continuity Management System Policy demonstrates how Gediz Elektrik Perakende Satış A.Ş. (the “Company”) approaches business continuity management.

The Company acts within the framework of the scope and goals determined as per the requirements of the ISO 22301 Business Continuity Management Standard and aims to recover any possible interruption in processes that support critical services in accordance with how it is stipulated in business-effect analyses and to help to resume normal business within planned periods.

The Company plans, establishes, regularly monitors and improves the Business Continuity Management System in order to manage any interruption that occurs due to extraordinary situations, prevent system and resource losses, as well as loss of reputation, and fulfill its legal liabilities.

To this end, our Business Continuity Management System aims to:

Ensure the health and safety of employees and customers as a priority in emergencies and other extraordinary cases,
Protect buildings and plants,
Coordinate and implement activities related to Crisis Management, Business Continuity, Information Technologies Disaster Recovery and Emergency Management,
Help to resume in the most effective way the normal business activities following a business interruption,
Minimize business interruptions for the company, customers, suppliers, stakeholders, and other critical shareholders,
Make sure that the applicable legal and regulatory legislation and contracts are complied with when it comes to the Business Continuity requirements,
Minimize the effects of business interruptions on the company from a financial, legal and reputational perspective,
Ensure the correct internal and external communication flow by conducting an effective decision-making process in case of an interruption,
Take the necessary corrective and preventive actions to manage any risks that may cause an interruption,
Continuously improve the system through planned training courses, awareness activities, and tests/drills,
Enhance the efficiency and quality of the Business Continuity Management.

Enerji Yönetim Sistemi Politikası

Enerji Yönetim Sistemi Politikası, Gediz Elektrik Perakende Satış A.Ş (“Şirket”) nin enerji yönetimine yaklaşımını göstermektedir.

Şirket, ISO 50001 Enerji Yönetim Standardının gereklerine göre belirlediği kapsam ve hedefler çerçevesinde; enerjinin etkin bir şekilde kullanılması, değerlendirilmesi, enerji sarfiyatına karşı gerekli önlemlerin alınması, enerji tüketiminin izlenmesi, kontrol altında tutulması ve enerji performansının sürekli iyileştirilmesini hedefler.

Bu çerçevede Enerji Yönetim Sistemi Politikamız ile;

- Enerji amaçları ve hedeflerinin oluşturulması, gözden geçirilmesi ve gerçekleştirilmesi için gerekli kaynağı ve desteği sağlamayı ve güncellemeyi,

- Enerji Yönetim Sistemimizi ve enerji performansını Şirketimizin amacına ve ölçeğine uygun olacak şekilde sürekli iyileştirmeyi, dokümante etmeyi, tüm çalışanlara duyurmayı, gözden geçirmeyi ve güncelliğini sağlamayı,

- Enerji ile ilgili tüm yasaları, yönetmelikleri ve diğer şartları takip ederek gerekliliklerini yerine getirmeyi,

- Enerjiyi kontrol altında tutacak uygun kaynak ve teknolojileri kullanmayı,

- Enerji tüketimini azaltmayı, enerji verimliliği ile ilgili sürekli gelişmeye yönelik iyileştirmeler yapmayı, bunları uygulamayı ve sonuçlarını takip etmeyi,

- Enerji performansının iyileştirilmesi için enerji verimli ürünleri kullanmayı, hizmetleri satın almayı ve tasarım faaliyetlerinde enerji verimliliğine öncelik vermeyi,

- Enerji duyarlılığı konusunda tüm çalışanlarımızın ve ziyaretçilerin bilinçlendirilmesine katkıda bulunmayı taahhüt ediyoruz.

Hizmet ve İletişim Politikalarımız

Kararlı, etkili ve güven veren iletişimimiz ile güçlü bağlar kuruyoruz.

Açık ve kararlı bir dil kullanarak, müşterilerimizin güven ve beklentilerini karşılayan iletişim modelleri geliştiriyoruz. Profesyonel ve etkili iletişimimizle güçlü bağlar kuruyoruz.

Müşterilerimizin sesine kulak veriyor, ihtiyaçlarını anlıyor ve bütün kanallarımızla en iyi hizmeti sunmayı amaçlıyoruz.

Müşterilerimizin sesine kulak vererek, ihtiyaçlarını anlamayı hizmet anlayışımızın merkezine koyuyoruz. Tüm kanallarımızda en iyi hizmet deneyimini sunmayı amaçlıyor, geri bildirimleri dikkate alıyoruz.

Yılların deneyimini yenilikçi bakış açısıyla birleştirerek müşterilerimize en uygun çözümleri sunuyoruz.

Dönemsel akımları, yenilikleri ve gelişmeleri sürekli takip ederek, müşterilerimize etkili, alternatif fikirler sunuyoruz. Deneyiminizi yenilikçi çözümlerle birleştirerek fark yaratıyoruz.

Management Commitment

As Aydem and Gediz Perakende, the group companies of Turkey's first integrated energy company Aydem Energy that touch the consumer, we work responsibly in order to touch every aspect of the lives of our customers, employees, suppliers and our society, and to produce solutions with innovative approaches, sustainable projects that will lead the sector and make a difference. We develop and implement. We create our business models with the awareness of serving the society, and we carry out our cooperation by directing all our stakeholders in this direction and taking them to our center.

As Gediz Retail, our top priority is; To provide a healthy and reliable working environment to all our employees by providing the highest standards in our risk and company management and to act with environmental awareness in our internal and external activities. In this direction; We build a sustainable future by integrating our responsibilities in the areas of quality, environment, occupational health and safety into all our business strategies, in line with our understanding and values that center the human, environment and sustainable operating system in all our internal and external activities.

In order to realize the targets and policies we have determined within the scope of the Integrated Management System, we effectively fulfill the requirements specified in the ISO 9001 Quality Management System, 14001 Environmental Management System, 45001 Occupational Health and Safety Management System and 10002 Customer Satisfaction Management System. Maintaining the sustainability of the system through continuous improvement is among our most important principles. In accordance with the Integrated Management System; By conveying the importance of legislation and legal conditions to our employees, we raise awareness of our employees about Integrated Management System practices and support their development.

As Gediz Perakende, we maintain our quality policies with the aim of being a reliable company in all our business processes with an understanding that meets the needs and expectations of our customers, ensuring that all our employees become people who can use their talents at the highest level within the framework of quality systems, and constantly increasing the quality level with teamwork.

In order to fulfill the Integrated Management System requirements in our business strategies in the most effective way, our company;

It accepts and confirms that the continuity of the Integrated Management System is extremely important for the company's employees and future strategic development plans.
It supports and encourages the use of continuous improvement, process approach and risk-based thinking by providing trainings and infrastructure investments related to the Integrated Management System throughout our company.
Managers at management levels lead the way in giving responsibility and support to the employees in their units regarding the Integrated Management System.
It provides the necessary foundations for the implementation of the Integrated Management System, which has entered into force and is being implemented, both inside and outside the company, and provides all necessary support for its dissemination by raising the awareness of the employees.
It continues its efforts to ensure that the system is understood by all employees, to allocate the necessary resources for the system to work efficiently, and to continuously improve the system.

Integrated Management Systems

Information Security Policy

There is no doubt that for Gediz Elektrik Perakende Satış A.Ş. (GEDİZ), which defines information as a critical asset that needs to be protected, information must be protected appropriately so that the Company can carry out its activities in a healthy manner and meet its legal requirements. Ensuring security of the information possessed and making sure that information is accessed by the right people at the right time is one of the most critical requirements for success today. GEDİZ guarantees that, thanks to appropriate checks and proactive measures, the security of the information it holds is handled within the framework of a management system. Any negative situation resulting from threats (loss, theft, damage, access by unauthorized persons, modification of information, malware, cyber attacks, hackers and spying, etc.) to the information systems would lead to serious consequences with regard to the Company’s liabilities and hinder the activities significantly. GEDİZ is aware of all of these threats and it protects its information assets against them. GEDİZ must ensure security of personal data and information assets so that it can fulfil its responsibilities towards regulatory authorities and company partners and, in particular, its customers. In all contracts signed by GEDİZ, including labor contracts of employees, it is underlined that all information that may be associated with the Company is “confidential information that must be protected” and that violating this rule will result in certain consequences. GEDİZ created an Information Security Policy with the aim of preventing security breaches, protecting all the company information stored in physical environments or on computer systems, and ensuring the confidentiality, integrity and accessibility of such information. The policy also sets out the responsibility of GEDİZ employees to protect the information. The principles and measures stated in this policy, the relevant procedure and other annexes represent the applicable objectives defined for GEDİZ.

Cookie Policy

The Gediz Perakende Cookies Policy was drawn up to provide information about the definition, intended use and types of the cookies used on the websites belonging to or operated on behalf of Gediz Elektrik Perakende Satış A.Ş. (“Gediz Perakende”), as well as on how to manage cookie preferences.

Gediz Perakende website uses cookies, web beacons and similar technologies (collectively referred to as “Cookie(s)”) in order to make it easier for visitors to navigate the website, offer them an enhanced experience that is better, faster and safer, understand user habits, needs and the services interested, and show ads.

If you use the websites or applications of Gediz Perakende, cookies may be used and installed on your device as per the Gediz Perakende Cookies Policy, and your personal data may be processed in line with the purposes and methods stated in the General Clarification Text as per the Legislation on the Protection of Personal Data under the following conditions.

We kindly remind you that you can change your cookie settings to manage the use of cookies, however, if you do so, you may not be able to use certain functions on the Gediz Perakende website.

What is a Cookie?

Cookies are simple and small text files that are usually comprised of letters and numbers and sent to computers, tablets and/or smart phones by the relevant server during the user’s visit to the website, and content and information of which can be accessed and read. Each cookie is exclusive to the web browser.

It is ensured that the cookies are saved to the hard drive during the current session with minimum memory usage and without risking the computer, tablet and/or smartphone. Cookies store your IP address, session details, pages you have accessed and other similar data. Cookies make sure that website preferences are remembered, session stays open and the user is provided with the content of their interest.

Most browsers accept cookies by default. Apart from this, they enable or disable security settings for temporary or stored cookies.

Cookie Categories

Strictly Necessary / Mandatory Cookies

These are technical cookies that ensure that the website operates properly and allow the user to make use of the functionalities on the website. They are required for the user to navigate and use special sections of a website, such as safe areas of a web page. Without the strictly necessary cookies, the user may not be able to use certain functionalities of the website. On an operational level, they are necessary for services, applications and tools. Visitor consent is not required for strictly necessary / mandatory cookies.

Performance Cookies

These cookies offer a more personalized user experience by ensuring that the website remembers the user’s specific choices such as language/region in their second visit to the website.

Functionality Cookies

These cookies collect information about the number of visitors to the website and how they use it. They are used to compile a website report. They are used with the aim of understanding how visitors use the website, measuring the performance of the website, optimizing and improving the website and making sure that the website is interesting enough and serves the intended purpose. Outputs from performance cookies show the pages viewed, pages from which the user was redirected, pages exited, time frames of visits, mouse movements, screen/page scrolling activities, information on whether the visitor received the intended error messages, and the terms searched on the website. These cookies do not identify users; they collect information anonymously.

Advertising, Marketing and Targeting Cookies

First-party cookies, third-party cookies and web beacons* are used with the aim of creating advertising campaigns tailored to the interests of website visitors and measuring the number of advertisements. These cookies are also used to measure the efficiency of advertising campaigns that the user interacts with during their visits to certain web pages and to allow communication with potential advertisers. Apart from discovering the interest in any advertisement, the cookies also use the technology to understand if the advertisements and content offered are beneficial. These cookies can be disabled by changing browser settings.

Web Beacons

These are small, short graphical symbols that work with cookies to identify visitor behaviors. They are also known as pixel tags and/or clear GIFs.

Types of Cookies

Session Cookies:

Session cookies are temporary cookies that end and are deleted when the browser session ends. They ensure that the website operates properly.

Persistent Cookies

Persistent cookies remind the actions preferred by the visitor on many websites, and are stored on the device even when the browser session ends or the computer, tablet or smart device is restarted. They remain on the device even after the browser is closed unless the visitor deletes them or unless they expire.

First-Party Cookies

First-party cookies are installed by the website visited.

Third-Party Cookies

Third-party cookies are installed and controlled by parties other than the website visited. In order to offer you a better, safer and faster experience, Gediz Perakende collaborates with third-party service providers that use the relevant technologies to provide advertisement and content and to measure and analyze websites. Gediz Perakende does not allow service providers to collect personal data of the visitors on the Gediz Perakende website for their own use, and the contracts signed mutually to this end are subject to legal restrictions set out in the Personal Data Protection Law.

Third-Party Cookies Used by Gediz Perakende:

Gediz Perakende does not use cookies to profile your behaviors on third-party websites, but it uses data provided by third parties to show you advertisements and promotional displays for products/services you might be interested in. None of the personal data collected through these advertisements is shared with third parties except for the business partners who carry out activities on our behalf under the confidentiality agreement of Gediz Perakende.

Social Media

Facebook Business (formerly Facebook Custom Audience)opt-out through company

Analytics/Measurement, Content Personalization, Optimization, Targeted Advertising, Advertising Services

https://cop.evidon.com/companies/facebook-custom-audience

Facebook for Developers (formerly Facebook Connect)opt-out through company

Analytics/Measurement, Content Personalization, Optimization, Targeted Advertising, Advertising Services

https://cop.evidon.com/companies/facebook-connect

Facebook Customer Audience Terms and Conditions

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Twitter

Publishing advertisements on Twitter based on your interaction.

https://support.twitter.com/articles/20170410

Youtube

Targeted advertising according to the cookies installed through direct links or videos placed on the website from YouTube

https://support.google.com/ads/answer/2662922?hl=en-GB

Publishing advertisements on LinkedIn.com, SlideShare.net or on a mutual third-party website of LinkedIn

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Reklam Ağları

Google Inc.opt-out through company

Analytics/Measurement, Content Personalization, Optimization, Targeted Advertising, Advertising Services

https://cop.evidon.com/companies/google

Yandex

Analysis/Measurement, Content Personalization, Optimization, Targeted Advertising, Advertising Services on Yandex

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Analytics Provider

Google Analytics opt-out through company

Analytics/Measurement, Optimization, Targeted Advertising

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Purposes of Using Cookies

They are used to sign online subscription contracts, complete all kinds of subscription processes and offer bill payment services.
If the user selects “Remember Me” under “Online Services” so that they are logged in automatically in their subsequent visit to the website, the cookies store and use their username and password.
They are used to analyze the website traffic.
They are used to better understand and remember how visitors interact with the website, to offer personalized experiences according to each visitor’s settings and to assess the experience offered.
They are used to ensure that the interactions with the website are faster and safer. They are also used to detect malicious activities and/or violations, but there is no guarantee on the certainty or accuracy of this function.
They are used to improve the performance of the website and offer ease of use.
They are used to redirect visitors to products and/or services they may need or be interested in considering their usage habits.
They are used to store personalized information on the website (if requested) to offer ease of use.
They are used to publish advertisements based on the products and/or services that the visitors are interested in, and to do remarketing to remind the visitors of their needs.
They are used to ensure legal and commercial safety of visitors and Gediz Perakende.
They are used to fulfill legal and contractual obligations, in particular those resulting from Law No. 5651 on the Management of Internet Broadcasts and Prevention of Crimes Committed through Such Broadcasts, and the Regulation on the Procedures and Principles for the Management of Internet Broadcasts.

Controlling, Disabling or Deleting Cookies

Browser settings can be used for processes such as changing cookie preferences or disabling or deleting cookies.
Browsers offer several options regarding the control of cookies, that allow the user to accept/decline cookies and/or accept/decline certain cookies and/or receive a warning when a website wants to install cookies on their device such as a computer, tablet or smartphone. However, most browsers may accept cookies by default.
What is also possible is that the cookies previously installed on your device such as a computer, tablet or smartphone may be deleted.
Cookies remain in use unless they are disabled and/or deleted.
Processes of controlling, disabling or deleting cookies vary depending on browser features.

Google Chrome (Bilgisayar, Android, iPhone and iPad):

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Mozilla Firefox:

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Internet Explorer:

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Opera (Bilgisayar):

http://www.opera.com/browser/tutorials/security/privacy/

Opera (Mobile):

https://help.opera.com/en/mobile/android/#privacy

Yandex:

https://yandex.com.tr/support/browser-classic/personal-data-protection/cookies.xml

Safari (Computer):

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Safari (Mobile):

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Android Browser:

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Google Adwords:

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Google Analytics:

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To manage cookie preferences on other browsers (such as Microsoft Edge), please see help or support pages of the relevant browser.

You can visit www.allaboutcookies.org to get information about cookies and how to delete or decline them.

We have security measures in place to prevent unauthorized access to the cookies and similar technologies on the Gediz Perakende website. Only Gediz Perakende and/or our service providers are allowed to access cookie data.

Gediz Perakende does not retain your personal data through cookies or similar technologies installed.

Gediz Perakende does not allow service providers to collect personal data for their own use, and the contracts signed mutually to this end are subject to legal restrictions set out in the Personal Data Protection Law.

Gediz Perakende’s cookie name, pixels and other technologies may change over time. Gediz Perakende reserves the right to make changes to the existing cookies, web beacons and other technologies and their types as the technologies and solutions evolve.

It is up to the visitor to use cookies or disable the relevant technologies.

If you believe that your personal data is collected or that there is a problem with different technologies, you are highly recommended to contact us at kvk.gediz@aydemenerji.com.tr.

Protection of Personal Data

Gediz Perakende General Clarification Text as per the Legislation on the Protection of Personal Data

Data Controller’s Identity

At Gediz Elektrik Perakende Satış A.Ş. (“Gediz” or the “Company”), we kindly bring the following to your attention under our liability to inform you to ensure that we can act in accordance with the Personal Data Protection Law No. 6698 (the “Law”) and the related regulations regarding the personal data we obtain from you as the data controller.

2.Processing of Personal Data and the Purposes for Processing

Your personal data is processed to ensure that our Company can offer the best services possible, although the purpose may vary depending on the services and commercial activities offered by Gediz. To this end:

Your personal data (identity, contact details, customer transaction data) and sensitive personal data (as per the Regulation on Electricity Market Consumer Services, such data can be indirectly obtained from your medical reports, and the religion and blood type details can be indirectly obtained from your identity card and/or driver’s license copy, if shared by you) are processed in a limited manner forcarrying out the subscription contract processes; following up the after-sales support services, customer relations management processes, customer satisfaction activities, legal/financial/accounting processes, and any requests/complaints; ensuring that the activities are in compliance with the Electricity Market Law and the secondary legislation, as well as other relevant legislations; conducting advertising/campaing/promotion/survey activities as part of the marketing analysis efforts and the marketing processes for the services offered; carrying out/auditing business activities; making audits; conducting activities to ensure business continuity; carrying out risk management processes; carrying out strategic planning activities; informing the authorized persons, entities and organizations if requested; carrying out communications activities; carrying out storage and archiving activities; carrying out information security processes and ensuring compliance with the policies and procedures of the Company and of the Aydem Holding group companies which the Company is affiliated with. Your personal data may also be transferred to physical archives and information systems to be stored in both digital and physical environments.

3.Parties to Whom the Personal Data Processed may be Transferred, and the Related Purposes

For the purposes set out in Article 2 of this Clarification Text, and depending on and limited to the reasons for transfer within the scope of the Law and the related regulations, your personal data collected may be transferred to the Energy Market Regulatory Authority and other governmental bodies and organizations; independent audit companies; law offices and attorneys; agencies; banks; our business partners; systems of Turkey-based information technology companies that we receive services from and collaborate with, including our suppliers; our Company’s domestic shareholders and group companies to carry out the operational processes and to get support from them and to databases used jointly with these companies.

4.Method and Legal Basis for Collecting Personal Data

As you are a customer of our Company, your personal data may be collected from the verbal or written information you provided to our Company through automated or non-automated means, from governmental bodies and agencies, from social media platforms, from the applications and software and the closed circuit camera systems used for the Company’s activities; for and limited to the legal reasons stipulated in Article 5 of the Law including express stipulation by law, establishment and performance of contracts, legal liabilities of the data controller, presence of an express consent, and legitimate interests of the data controller.

5.Your Rights under Personal Data Protection

As per the legislation on personal data protection, you have the rights to find out if your personal data has been processed; request information regarding the processing of your personal data if processed; find out the purpose for processing the personal data and if the data is used by us in line with such purposes; find out the third parties to whom your personal data is transferred at home and abroad; request correction if your personal data was processed incompletely or incorrectly and request that the third parties to whom the data was transferred (if transferred) be informed of such procedure; request deletion or destruction of your personal data if the conditions that require processing of such data are no longer valid and request that the third persons to whom the data was transferred (if transferred) are informed of such procedure; raise an objection if you believe that there is a consequence to the detriment of you due to the fact that the processed data was analyzed by automated systems exclusively; and request compensation if you incur any loss due to unlawful processing of your personal data.

According to the Law, for your applications regarding your personal data, you can fill out the form on https://gedizperakende.com.tr/ and

Bring it to the address Adalet Mahallesi, Anadolu Caddesi, Megapol Tower No:41 İç Kapı No:211 Bayraklı/İzmir , ensuring that your identity is authenticated or
Send it to gediz.perakende@hs02.kep.tr or ;
Send it to kvk.gediz@aydemenerji.com.tr from your email address registered at our Company or
Submit it via other methods stated in the Law and the relevant legislation, ensuring that your identity is authenticated.

As per Article 13 of the Law, our Company will conclude application requests as soon as possible and, in any case, within 30 (thirty) days at the latest depending on the nature of the request. If the process incurs any cost, the tariff determined by the Personal Data Protection Board shall apply. If the request is rejected, the reason(s) for rejection shall be justified in writing or in electronic environment.

Gediz Perakende Customer Clarification Text as per the Legislation on the Protection of Personal Data

1. Data Controller’s Identity

2. Processing of Personal Data and the Purposes for Processing

Your personal data (identity, contact details, customer transaction data) and sensitive personal data (as per the Regulation on Electricity Market Consumer Services, such data can be indirectly obtained from your medical reports, and the religion and blood type details can be indirectly obtained from your identity card and/or driver’s license copy, if shared by you) are processed in a limited manner for carrying out the subscription contract processes; following up the after-sales support services, customer relations management processes, customer satisfaction activities, legal/financial/accounting processes, and any requests/complaints; ensuring that the activities are in compliance with the Electricity Market Law and the secondary legislation, as well as other relevant legislations; conducting advertising/campaing/promotion/survey activities as part of the marketing analysis efforts and the marketing processes for the services offered; carrying out/auditing business activities; making audits; conducting activities to ensure business continuity; carrying out risk management processes; carrying out strategic planning activities; informing the authorized persons, entities and organizations if requested; carrying out communications activities; carrying out storage and archiving activities; carrying out information security processes and ensuring compliance with the policies and procedures of the Company and of the Aydem Holding group companies which the Company is affiliated with. Your personal data may also be transferred to physical archives and information systems to be stored in both digital and physical environments.

3. Parties to Whom the Personal Data Processed may be Transferred, and the Related Purposes

4. Method and Legal Basis for Collecting Personal Data

5. Your Rights under Personal Data Protection

According to the Law, for your applications regarding your personal data, you can fill out the form on https://gedizperakende.com.tr/ and

Bring it to the address Adalet Mah. Anadolu Cad. No:41 Megapol Tower Kat:19 35530 Bayraklı/İZMİR , ensuring that your identity is authenticated or

Send it to gediz.perakende@hs02.kep.tr or

Send it to kvk.gediz@aydemenerji.com.tr from your email address registered at our Company or

Submit it via other methods stated in the Law and the relevant legislation, ensuring that your identity is authenticated.As per Article 13 of the Law, our Company will conclude application requests as soon as possible and, in any case, within 30 (thirty) days at the latest depending on the nature of the request. If the process incurs any cost, the tariff determined by the Personal Data Protection Board shall apply. If the request is rejected, the reason(s) for rejection shall be justified in writing or in electronic environment.

Gediz Perakende Prospective Employee Clarification Text as per the Legislation on the Protection of Personal Data

1.Data Controller’s Identity

2. Processing of Personal Data and the Purposes for Processing

As you are a prospective employee, your personal data including your identity, contact details, professional experience, physical location security, family member details, visual data and your resumé that you provided to our Company, and your sensitive personal data including your medical and association membership data (if you have submitted) shall be processed, as part of the job application processes, to carry out the employee application processes and the selection, offer and recruitment processes; obtain camera recordings to ensure physical location security should you visit our Company; check references; ensure information and data security and to make sure that, if you are not recruited, we can assess your resumé for a potential future position or for an appropriate position at our group companies and that we can contact you in this regard. In addition, if you give your express consent, the said data shall be transferred to physical archives and information systems to be stored for 12 months in both digital and physical environments.

3. Parties to Whom the Personal Data Processed may be Transferred, and the Related Purposes

For the purposes set out in Article 2 of this Prospective Employee Clarification Text, and depending on and limited to the reasons for transfer within the scope of the Law and the related regulations, your personal data collected may be transferred to references, to Aydem Holding group companies which the Company is affiliated with, to databases used jointly with these companies and, if required, to governmental bodies and organizations.

4. Method and Legal Basis for Collecting Personal Data

Your personal data is collected in physical or electronic environments from the verbal or written applications made using our Company’s website or email address or made in person, from consultancy firms and from the information provided during interviews, from information provided by references and through closed circuit camera systems, in line with the basic principles stipulated in the Law and for and limited to the legal reasons stipulated in Article 5 of the Law including establishment of contracts, legitimate interests of the data controller, and presence of an express consent.

5. Your Rights under Personal Data Protection

After filling out the Information Request Form on Personal Data Protection Law (KVKK), you can:

Bring it to the address Adalet Mahallesi, Anadolu Caddesi, Megapol Tower No:41 İç Kapı No:211 Bayraklı/İzmir, ensuring that your identity is authenticated or

Send it to gedizepsas@hs02.kep.tr or

Send it to kvk.gediz@aydemenerji.com.tr from your email address registered at our Company or

Send it via other methods stated in the Law and the relevant legislation, ensuring that your identity is authenticated.

Under the Law, for your applications regarding your personal data, you can click the button below to download the Information Request Form on Personal Data Protection Law and fill it out and

Adalet Mahallesi, Anadolu Caddesi, Megapol Tower No:41 İç Kapı No:211 Bayraklı/İzmir

Submit it through online services on our website or ,

Send it to kvk.gediz@aydemenerji.com.tr,

Submit it via other methods stated in the Law and the relevant legislation through our Companys Customer Relations Centers (ensuring that your identity is authenticated).

PPD Information Request Form

Privacy Policy

It is of great importance for us to protect your personal data and the privacy of your personal life.

At Gediz Elektrik Perakende A.Ş. (the “Company”), information belonging to users that interact with the web page or online channels is considered confidential information as per the information security policy of our Company.

We would like to inform you regarding the collection, processing and transfer of the personal data you provide to our Company, and the relevant legal rights you can exercise.

Processing of Your Personal Data and the Purposes for Processing

Your identity details, contact details, audio and/or visual records, and all kinds of information and documents that are obtained as a result of your use of our company website and that can make you identified or identifiable, as well as any other additional details you have or will provide to the Company are considered personal data. Your personal data can be processed by the Company as the data controller.

Method and Legal Basis for Collecting Personal Data

Your personal data stated above is collected in physical or electronic environments, depending how the data has been transferred to the Company, through the website, social media accounts, mobile apps and the documents you submit in the events organized by the Company, and is processed based on your express consent in order to monitor and carry out the Company’s product and service loyalty processes, legal processes, communication activities, analyses, storage and archiving activities, social responsibility and civil society activities and strategic planning activities, to follow up on requests/complaints, to inform authorized persons, organizations and institutions, and to improve service quality.

In addition to the above, we may collect, process and transfer your personal data in cases where (i) there exists at least one of the situations expressly stipulated in applicable laws available in the Republic of Turkey, (ii) the aforementioned activities are mandatory in order for us to fulfill our legal obligations as the data controller, (iii) your personal data was made public by you, (iv) data processing is obligatory in order to establish, exercise or protect a right, (v) data processing is obligatory for legitimate interests of the data controller, on the condition that such processing does not harm your fundamental rights and freedoms.

Transfer of Your Personal Data

With the aim of carrying out our activities and fulfilling the purposes stated above, and in line with the principles set out in Articles 8 and 9 of the Personal Data Protection Law No. 6698 (the “Law”), any personal data you provide to our Company may be transferred, where necessary, to the group companies of Aydem Holding, third parties we collaborate at home or abroad, authorized and contracted public/private legal entities, as well as to our direct/indirect and domestic/foreign subsidiaries, and other third parties including organizations and institutions we receive services from or collaborate with in order to meet other needs of the Company within the scope of its area of activity, on the condition that such transfer is done in line with the relevant legal restrictions and is limited to the purposes stated herein, and such personal data may also be transferred to official bodies and institutions if there is a legal obligation to do so.

Furthermore, as per Article 9 of the Law, your personal data/sensitive personal data may be transferred to persons and organizations based in foreign countries that have an adequate level of protection as determined only by the Personal Data Protection Board (the “Board”); and for countries that are determined and announced to not have an adequate level of protection, such data may be transferred to persons and organizations for which the data controllers in Turkey and in the relevant foreign country guarantee an adequate level of protection in writing, limited to the situations where permission is obtained from the Board for such transfer. To this end, your express consent is required as per the principles set out in paragraph two of Article 4 of the Law, and your express consent is not required in cases of the situations stated in paragraph two of Article 5 and paragraph three of Article 6 of the Law.

Your Rights

According to the legislation on the protection of personal data, you have the right to:

a) Find out if your personal data has been processed; 

b) Request information on the processing of your personal data if the data has been processed;

c) Find out the purpose of processing your personal data and if the data has been used for the intended purpose; 

d) Find out the third parties to whom your personal data has been transferred at home or abroad; 

e) Request rectification if your personal data was processed incompletely or incorrectly; 

f) Request deletion or disposal of your personal data according to the conditions set out in the Law; 

g) Request that the third parties to whom your personal data has been transferred be informed about the fact that your personal data that was previously processed incompletely or incorrectly was rectified, or that your personal data was deleted or disposed of;

h) Object to the results of processing your personal data through automated means if you believe that analyzing your processed data exclusively through automated systems led to a result that is against you; 

i) Request compensation if you suffer any loss/damage due to unlawful processing of your personal data.

With regards to exercising the rights above, you can send an email to kvk.gediz@aydemenerji.com.tr or an application letter to Adalet Mahallesi, Anadolu Caddesi, Megapol Tower No:41 İç Kapı No:211 Bayraklı/İzmir . If your application requires an additional fee, you may be charged the fee that is stated in the tariff determined by the Personal Data Protection Board.

Code of Ethics and Working Principles

Ethics Hotlines

Digital Form: https://www.aydemenerji.com.tr/etik-hat

For your questions and reports, you can use the contact channels below or directly contact the members of the Ethics Committee.

E-Mail : etik.gedizperakende@aydemenerji.com.tr

Tel : 0 (850) 575 0 575

Posta address: Adalet Mah. Anadolu Cad. No:41 Megapol Tower Kat:19 35530 Bayraklı/İZMİR (To the Office of Ethics Committee)

Purpose and Scope

In the simplest terms, ethics analyze the generally accepted standards of judgment recognized all around the world in terms of human relations. Business ethics are, on the other hand, the set of principles developed to guide behaviors in the business world.

Aydem Enerji’s core values and principles guide our code of business ethics while at the same time constituting the expectations, standards and ethical practices that are the basis of all our business relationships and operations.

The Code of Ethics and Working Principles of Aydem Enerji define Aydem Enerji Anonim Şirketi and all its affiliates (Aydem Enerji) and all third parties acting on behalf of them, as well as the rules that the employees must follow, rights of employees, and ethical valuation and basic principles of the Company.

Our Responsibilities as Employees

We need honesty and integrity from our employees in order to maintain the reputation, reliability and achievements that we have gained following the lead of our leaders. Behaviors that are unethical or in contradiction with our working principles can never be accepted or tolerated. It is the responsibility of each and every employee to protect the reputation and success of Aydem Enerji.

Each employee must do their best in professional terms to meet the needs of internal and external customers within the scope of their respective job. Employees must also work efficiently to contribute to their own objectives, as well as those of their departments and of the Company, and to meet customer needs.

Each and every one of us must especially:

Act in compliance with the core ethical and human values and the corporation’s strategies when fulfilling our duties;
Act within the framework of honesty and reliability, establish and maintain equal relationships with people, collaborate with other employees to reach common goals and use the Company’s assets and resources efficiently, effectively and respectably;
Demonstrate behaviors and work ethics that comply with the “Code of Ethics and Working Principles” announced across the Company, read, understand and abide by all principles of our Company;
Comply with all laws and principles, as well as all applicable legislations and regulations set out by the relevant regulatory authorities (Energy Market Regulatory Authority, Capital Markets Board, etc.) and the professional organizations where Aydem Enerji is a member, when fulfilling our duties;
Act as per the fair competition principles and avoid unfair competition in all operations and in all relationships with other financial institutions;
Never forget that being open, complete and honest with all our shareholders is part of our identity and reliability, and always act to improve the reputation of Aydem Enerji.

When doing our jobs as employees, each one of us must have the required common sense and make the necessary efforts, consider profitability and efficiency principles, and avoid all kinds of actions and operations that may cause loss to the Company. We must keep in mind that any behavior that violates or exceeds the limits set by our “Code of Ethics and Working Principles” may result in an ethics or disciplinary investigation as these code of ethics and working principles are considered the guarantee of our Company’s reputation.

Our Company expects its managers and all other employees to make judgements that comply with the “Code of Ethics and Working Principles” when fulfilling their duties. It is important for our managers and all other employees to frequently refer to these rules and to regularly check whether they are acting in compliance with the “Code of Ethics and Working Principles” and their purpose so that they can fulfill their duties in the most efficient and correct way possible in line with the Company’s goals.

As a company we are aware of the fact that the rules in this manual do not completely cover every question or every situation. In such cases, and for all your questions or opinions about the “Code of Ethics and Working Principles”, you can contact the Code of Ethics Consultant and the Human Resources Management.

Below is the contact channel provided for you to submit your questions regarding the “Code of Ethics and Working Principles” or to report those who violate the “Code of Ethics and Working Principles”, or the suspicious situations that may harm our reputation.

E-Mail : etik.gedizperakende@aydemenerji.com.tr

Tel : 0 (850) 575 0 575

Posta Adress :To the “Office of Ethics Committee” of İzmir given on the website of our Company

Privacy

Ensuring Privacy in the Company

Our employees:

Are responsible for abiding by the details in Aydem Enerji Information Security Policy and the applicable legislation, with regard to information security.

Can under no circumstances use the personal or financial information of a customer, supplier or another employee without authorization/for non-business purposes (except for the disclosure of the information and documents requested by authorized persons or bodies as stated in the law and other legal regulations).

Cannot share the information or the documents they have as part of their jobs with internal or external unauthorized persons or organizations for any reason, or use them for speculative purposes (directly or through third parties).

Know that the work they produce within the scope of their jobs (such as projects, technical infrastructures, regulations, etc.) is the property of Aydem Enerji, and can never take the same or other similar efforts out of the Company without the prior written approval of the top executive of the Company.

Do not share any personal rights that must be known only by them with other internal or external parties.

Avoid criticizing the general policies of Aydem Enerji as such expressions may harm the company reputation.

Cannot discuss matters related to their duties while not on duty, and do not cause any circumstances that may lead to a speculation or a negative opinion.

Continue to be obliged to protect the personal and financial information of customers even if they leave their jobs at the Company for any reason. It is prohibited to take the confidential information out of the Company, share it with third parties or use it for personal matters outside the Company.

Protecting the Personal Data of Customers

It is of utmost importance for the credibility and reputation of Aydem Enerji that our employees follow the standards of professional behavior that ensure the relationship and information privacy between the Company and its customers. Discussing or talking about confidential information related to customers or transactions outside the regular business activities or in public areas including third parties could cause violation of such privacy.

Our employees must use any personal data they access as part of their jobs in compliance with the Personal Data Protection Law (KVKK) and the complementing legislations, company policies and procedures.

Use of the information obtained as part of the job or internal authority is limited to the situations where such use is absolutely necessary for the legitimate and appropriate business purposes of Aydem Enerji.

Consumption, address or identity details of eligible consumers must never be shared for the benefit of other retail/wholesale electricity companies.

In addition, information on how we handle our daily tasks (such as our strategic plans and products) and the non-public information related to customers must be used with due consideration. Even the slightest implication in this regard may cause misunderstanding.

If the employee leaves their job at Aydem Enerji for any reason, they continue to be obliged to protect the privacy of the information.

Company-Owned Information

Non-public information about the Company’s customers and other third parties, as well as any such transactions, computer software, know-how, materials, records, files, papers, programs, reports, reviews, data, client lists, trade secrets and all other information are the property of Aydem Enerji and cannot be used for non-business purposes.

Our employees are not authorized to disclose such information to any third party. Such information can under no circumstances be shared with or disclosed to a competitor or any third party during or after services.

Equipment and materials entrusted to the employees by the Company for their work are not considered personal belongings. Furthermore, the Company reserves the right to monitor, based on applicable laws, the employees’ user accounts and the electronic communication channels such as the email accounts, phones, computer systems and other electronic records entrusted to them for business purposes.

Storing Information

It is the responsibility of the employees to be familiar with all the policies on how to handle, distribute, transmit, store or dispose of the information in a safe manner. In addition to the following matters, all employees are obliged to abide by the provisions in the “Information Security Policy” published/to be published by the Company.

As Aydem Enerji employees, we are expected to follow these basic policies:

Restricting Access to Confidential Information

All access to computers must be limited to the information required to handle daily tasks. Should there be a need to share information with parties outside the Company, this necessity must be examined in detail and if needed, it must be discussed with the Information Security Management and the relevant Code of Ethics Consultant.
When sharing information with authorized persons, the information required must be shared at the required level only.
Confidential information must be stored in places where it can be seen and accessed by authorized persons only. When not in use, documents containing confidential information must be stored securely in a drawer or cupboard, and not be left in fax machines, printers or other unsafe places.
If distributed within the Company, confidential information must be put in an envelope with the word “Proprietary” written on it.

Protecting Information on Computer Hardware

Laptops and other portable devices are quite vulnerable to theft. Such portable devices (computers, tablets, radio devices, mobile phones, etc.) must not be left in unsafe places. If a device entrusted to an employee gets lost or stolen, this must be reported to the Information Security Management and Human Resources Management in the shortest time possible.
Before leaving their computers, the employees must make sure that they lock them or log off the system.
User IDs and passwords are private information and must never be shared with anyone. The employee may be held responsible for the consequences of the use of the user ID or password, including unauthorized use, and of the damages to the company resulting from potential misuse. If you suspect that the user ID or the password is in danger, you must change the password and contact the Information Security Management.
Configuration of the antivirus software installed on the computer provided by the Company cannot be changed. It is the employee’s responsibility to protect the computer entrusted to them by the Company against the viruses that are sent to the employee externally and that may expose company information.

Internal and External Relationships

Relationships with Governmental and Public Bodies

The Company’s relationships with public administrations, political organizations, unions and other organizations must be based on the highest level of honesty, integrity, equality and independency.

Relationships with Customers, Suppliers and Other External Organizations

Our employees act in compliance with the principal of integrity in their relationships with customers, shareholders, affiliates and other firms on behalf of our Company.

At Aydem Enerji, our main objective is to meet the needs of our customers. The level of customer satisfaction defines the success or failure of our Company, which is why our customers are the most important elements of our business. Ensuring customer satisfaction is the best advertisement we can possibly have. For this reason, customer relations management at the Company are based on the principles of professionalism, kindness, and above all, seriousness and reliability. Maximum level of honesty, equality and compliance with law must be maintained in customer relationships.

Employees must provide customers with complete and clear information regarding the products and services offered by the Company. Employees are not authorized to give misinformation in order to gain higher profits. Our customers are clearly informed about their rights and liabilities in the activities they carry out with Aydem Enerji, and about the benefits and risks of the products and services offered to them. For this reason, our employees are obliged to be knowledgeable about both Aydem Enerji and the products and services offered by the Group Companies. It is prohibited to use sales or communication techniques that are against the professional code of ethics, that give misinformation to the customer about the products and services, or that try to force the customer in the decision-making process.

In addition to protecting the Company’s benefits from the activities carried out in the free market economy, employees avoid actions that may cause unfair competition based on the principles to ensure continuous trust in the energy sector, make efforts to improve the sector and work for joint interests. Employees, during the course of their duty, also do not express opinions or make comments -positive or negative- about competitors or their products and services.

The above-stated rules also apply to the relationships with suppliers. For relationships with persons or organizations from which we receive consultancy services, privacy conditions must be secured clearly with an agreement. On the other hand, an employee whose employment with the Company has been terminated can work at the Company for a temporary period as a consultant subject to a proposal by the manager of the relevant business unit followed by a review of the Human Resources Director and approval of the CEO.

None of the Aydem Enerji employees can officially or unofficially make an actual or apparent commitment on behalf of Aydem Enerji without authorization according to the approved procedures, nor can they work with those who harm social ethics, the environment or public health.

All Company employees must avoid all kinds of activities, practices and actions that are against the competition law, especially misuse of dominant position. Relevant rules are set out in the Competition Law Manual.

Media Relations

In Aydem Enerji’s relationships with the press, our employees must avoid any act that may cause speculations or a negative opinion about our Company, and must refrain from practices and behaviors that may damage the reliability, reputation and consistency of our Company or the sector, or that may lead to unfair competition.

Before the public and in areas where the audience thinks we are talking on behalf of the Company, we should not express our own opinions, but the Company’s opinions only. Media relations for Aydem Enerji as a whole are handled by the Directorate of Corporate Communications. All external relations are maintained as per the procedures set out by the Company. All demands, interview requests and questions from print and verbal media must immediately be forwarded to the Corporate Communications Management Units at Aydem Enerji.

For all contact details to be provided to third parties, prior approval must be obtained from the Directorate of Corporate Communications. Only authorized persons are allowed to engage in communications about the Company and the Company’s policies, practices and procedures.

In posts shared on social media platforms, blogs, forums and emails, we avoid expressions that may cause third parties to assume that we are sharing the post on behalf of Aydem Enerji.

The Aydem Enerji Digital and Social Media Principles Document is the basis for representing the corporate structure on social media.

Conflicts of Interest

Aydem Enerji does not prevent their employees from engaging in external activities that will not cause them to neglect their internal responsibilities, that will not stop them from acting in line with the Company’s interests, and that are in compliance with our “Code of Ethics and Working Principles”. However, employees engaged in such activities must avoid possible or actual situations that cause conflicts between the Company’s interests and their own interests.

A “Conflict of Interest” arises when the personal interest of an employee and that of the Company affect/prevent each other. For example, an employee’s responsibilities or obligations that serve their own interests outside the Company or in their personal life may make it difficult for that employee to objectively/impartially and efficiently fulfill their responsibilities and tasks related to their job at the Company. A conflict of interest can also arise when one of the family members of an employee gains a personal benefit because of the employee’s position at the Company.

Any action or relation that may lead to a conflict of interest must be reported to the relevant Code of Ethics Consultant.

In order to prevent potential conflicts of interest, our employees:

Avoid situations that would lead to an actual conflict of interest or the impression that there is a conflict of interest in favor of them or of the people related to them, and do not take part in the decision-making process for matters that are associated with their interests or that of the people related to them.
Do not engage in any kind of personal financial relationship with the customers or suppliers, and do not use their business relations to gain personal benefits.
Do not allow gift or benefit proposals that might affect their decisions or consent, or that might create a conflict of interest.
Efficiently use the assets and resources of the Company only for the Company’s interests and benefits.
Use their time and efforts for the Company, do not take on any other responsibility that would cause a conflict of interest, and do not work for another natural person or legal entity outside the Company.
Comply with the principles of honesty and transparency, keep the required distance and maintain an unbiased attitude in their relationships with public bodies and institutes.
Protect the secrets of the Company and the customers, and make sure that the Company’s proprietary information that would offer a competitive advantage is not taken out of the Company.
Do not use the information they have as per their jobs to get ill-gotten gains.

Corporate Opportunities

When doing their jobs, employees from all levels must have the required common sense and make the necessary efforts, consider profitability and efficiency principles, and avoid all kinds of actions and operations that may cause loss to the Company. When there is an opportunity that will provide benefits for our Company, our employees are responsible for seizing such legal business opportunities.

Employees are not authorized to make decisions or carry out activities that are against the Company’s interests or not related to their responsibilities. In case of a potential conflict, the employee must immediately report the situation to the relevant Code of Ethics Consultant.

In case an opportunity arises for the benefit of Aydem Enerji as a result of the use of Aydem Enerji’s assets or information or through the relevant job position at the Company, the employee must avoid not using this opportunity because it is against their own interests, and avoid preventing other employees from using the opportunity.

Prohibition on Borrowing

Our employees can under no circumstances borrow money or gain benefits from or engage in a bailing relationship with customers or third parties during the course of or in relation to their duties.

Our employees must manage their personal and financial affairs in a responsible manner and must not go into debts that they cannot pay back. Our employees must have a balanced and consistent attitude with respect to their financial position both in their personal and professional lives.

While any debit/credit relationships are prohibited between the superiors-subordinates at the Company, employees also cannot be engaged in such a debit/credit relationship with the customers, suppliers and contractors.

Bribery

Bribery means directly or indirectly offering payments or interests to our employees to gain unlawful benefits or affect decisions and practices. Bribery can take many forms such as cash or non-cash payments, expensive gifts, offering the employee an advantage to serve their interests, etc. When an employee is offered bribe by any person, company or organization, that employee must immediately report it to the relevant Code of Ethics Consultant.

Political Activities

When fulfilling their duties, employees of the Company must not become members of political organizations using the Company’s name. In their personal memberships, on the other hand, they are obliged to avoid any activities that may harm the Company’s interests or reputation and adversely impact the working hours.

None of our employees can engage in political resource management or campaign activities at the workplace or use the Company for such activities.

Political Contributions

It is prohibited to make donations on behalf of Aydem Enerji (in cash or in any other way) to political parties, political organizations and the representatives and candidates of such groups, directly or indirectly, in order to gain advantages for the Company. Our employees must avoid situations that may imply monetary or moral support to political parties on behalf of Aydem Enerji.

Gift Acceptance

It is of great importance that the gifts sent to our employees due to their positions do not cause any suspicion in the eyes of third parties regarding the impartiality of our corporate judgements and decisions. Preventing inappropriate relationships with third parties that may harm the reputation of Aydem Enerji is only possible through a corporate approach and implementation with regards to gift acceptance. For this reason, our employees must follow the rules below when it comes to accepting gifts.

Our employees cannot request or accept an object/service that is above the nominal value (100 USD) for any transaction or business, or cannot request or accept cash, check, etc. of any value.

Same rules apply even if the person does not gain a direct advantage from this valuable object. Similarly, it is not allowed to accept something valuable on behalf of a third person or party.

Our employees must not accept or request gifts, entertainment or other offerings that may or aim to affect the preferences and decisions of our Company.

An employee who received a gift that is not in compliance with the rules above must inform their manager and return the gift to the person or organization who sent it. In cases where one cannot be sure if the gift is appropriate or not, a written approval must be obtained from the relevant Code of Ethics Consultant.

If it is determined that returning a gift with a value above 100 USD is not practical or may lead to a situation that is not desirable in terms of the business relationship in question, acceptance and use of the said gift is only possible upon written approval by the relevant Code of Ethics Consultant. In such cases, acceptance of the gift must at the same time (e.g. within 24 hours) be reported to the Directorate of Internal Audit and Control.

All gifts that have a value at or above 100 USD must be recorded by the Management, and the gift acceptance reports created must be stored by the Managers to be submitted to the Code of Ethics Consultant when necessary.

Furthermore, in order to prevent the relevant organization from sending similar gifts in the future, a thank you letter could be sent to them, explaining the principles and practices of our Company in this regard.

All employees are obliged to follow the procedures above and report any actual or suspected situation that is against these procedures to the relevant Code of Ethics Consultant and the Human Resources Management.

Offering Gifts and Donations

Gifts can be offered to customers, business partners or supplier representatives on behalf of the Company in order to maintain the business relationship. However, no matter what their value is, gifts must be of a nature that does not impact any decisions to be made within the scope of the principle of honesty and business relationships.

The process must comply with the principles set out by the Aydem Enerji management and the general practices and must not damage the reputation of the Company. Principles regarding acceptance of gifts, invitations and donations are also valid in the process of offering them, and the 100 USD limit will apply.

Acceptance of Activities Where Third Parties Are Sponsors or Cover the Expenses

Our employees must not accept entertainment, free training, seminars, accommodation, trips, meals, etc. that are aimed at influencing their business decisions.

However, the Company agrees that rejecting such offers in certain cases may harm the relationships with customers. For this reason, any free of charge offers that third parties or existing or potential customers make to our employees to attend a conference, promotional meeting, training, etc. can be accepted only upon written approval by the top executive of the relevant function and the relevant Code of Ethics Consultant.

Transactions

Accuracy of Records

It is vital for the continuity and future of Aydem Enerji’s success to ensure integrity, accuracy and reliability in all kinds of records, documents and financial statements issued for Aydem Enerji. For this reason, our employees are obliged to ensure that the records and documents are accurate and in compliance with the law in all transactions they carry out on behalf of Aydem Enerji.

In addition to the accounting and auditing records, these documents also include time records, credit documents, phone records, transactional records and all the other records that are parts of our daily workflow. All records must accurately and timely reflect the transactions performed, and in case of a mistake, it must be remedied immediately.

If any deception, modification and/or negligence is detected in the general activities of the Company, it must immediately be reported to the Code of Ethics Consultant and the Human Resources Management or the relevant unit of the Company.

Stock Transactions of Employees - Insider Trading

Within the scope of the duty of loyalty, and the principles to protect the company interests, it is natural for our Company to have certain expectations from its employees. As part of these expectations:

It is possible for the employees to perform investment activities on the stock market with their shares at Aydem Enerji, on the condition that such activities comply with the regulations set out by the Capital Markets Board. However, employees acknowledge that using confidential information of Aydem Enerji or giving it to third parties with the aim of gaining benefits, including buying/selling shares on the stock market directly or indirectly, is considered insider trading and that such actions constitute a crime as per the law. Internal procedures that are created to implement the regulations of the Capital Markets Board are applied strictly. Employees listed in the document “with knowledge that may lead to insider trading” are expected to ensure full compliance with the relevant legislation and the company policies and procedures.

According to Additional Article 1: “Transaction Ban on Public Offerings” in the “Principles of Sales Methods for Public Offerings of Capital Market Instruments” No.22, Serial No. VIII of the Capital Markets Board: “When capital market instruments are being sold through public offering, issuers who issue and offer to public the capital market instruments, and the chair and board members, statutory auditors, deputy managers, general managers and deputy general managers, and other personnel that may have information as part of their jobs -as well as their spouses and any first degree relatives by blood or marriage- at the intermediary firms that mediate such public offering cannot directly or indirectly purchase the said capital market instruments.”

Aydem Enerji employees except for those stated in the above notice may participate in public offerings made by Aydem Enerji companies or other intermediary firms.

Company Resources

Using Company Assets and Resources

Any kind of property, asset, equipment, vehicle, computer, computer software, etc. that belongs to the Company and is provided to the employee to perform daily tasks cannot be used by the employee for personal benefits or for another person’s interests.

Company phones, personal computers, copiers and fax machines, supplies, postal services, emails, notice boards and meeting rooms are principally for company use. Using these or other company resources for personal purposes may harm the information flow, which is critical.

Company phone and the company address, email, internal communication and messaging system must not be used for personal correspondence or communications. Attention must be paid to keep personal phone conversations short.

When using resources on behalf of Aydem Enerji companies, we consider the Company’s interests and pay attention to protect the company assets. We avoid losing, damaging, misusing and wasting the Group’s assets. If there is no benefit to the Company, we do not use the Company’s assets or facilities under any name whatsoever for purposes other than company business, regardless of whoever benefits from such use. If there is a public interest or obligation, approval must be obtained from the General Manager of the relevant business unit.

Use of Technology

Aydem Enerji’s internet and intranet system is for business-related activities, communications and research. It cannot be used for other purposes (to watch movies/shows, etc.) and/or for obscene, pornographic or terrorism-related purposes. In addition, employees must not install or use unlicensed software on company computers. It is strictly forbidden to use company mobile devices to send messages that are harassing, threatening or that could damage the reputation of the Company.

External Assignments

Employees cannot engage in works that require them to be considered merchants or tradespeople (“Mercantile business” or “Tradesperson business”) directly or indirectly, cannot serve as a board member or auditor at companies other than Aydem Enerji companies without written approval from the relevant top executive, and cannot work for a fee or free of charge in any commercial business of natural persons or legal entities without prior written approval.

An employee may receive offers to participate in external activities as a paid or unpaid speaker or consultant due to the experience they have gained over the course of their business life. Such opportunities must be reviewed by the top executive of the relevant business unit and Corporate Communications Director in order to determine if there is a conflict between personal and corporate interests.

Business-Related Communications and Records

All kinds of communication, either written or verbal, must be professional and in compliance with our code of ethics. What we say, what we write and what we do must clearly reflect the ethics and expectations of Aydem Enerji, and must indicate the existence of a healthy, personal judgement. We must always avoid exaggeration, misguidance, lexiphanicism, extremely short statements, legal speculations, and words and behaviors that belittle persons, companies, or their products and services.

Everything that the employees say, write and do must be aimed at protecting and reflecting the honesty and reputation of Aydem Enerji. This policy applies to all types of communication including voice messages, emails, official notes and reports.

Email

An email is an important way of communicating internally and externally. Emails are records that can be disclosed only if it is legally obligatory to do so; otherwise, they must be kept confidential. An email that does not comply with our code of ethics can under no circumstances be written or sent.

All emails must be created considering the fact that they might be used as legal records, and must be written in a formal language. All kinds of messages must be sent according to all applicable policies and protected against unauthorized access.

Basic rules to be followed when handling emails are as follows:

Emails are used when required by the job.
When writing an email, it must be remembered that it can be considered a written record; therefore, it must be written using respectful, open, honest and precise statements. Hyperbolic statements, frivolous language, slang or derogatory remarks must be avoided when writing emails.
Replies must contain adequate information to avoid any misunderstanding. Email communications must comply with our code of ethics and policies, as well as the nature and purpose of such communications, and each message must be carefully reviewed before being sent.
Our standards for information protection and security also apply to email communications. Because email messages are sent to recipients outside the Company via public networks such as the internet, and they may stop or be misdirected in this process. For this reason, extreme care must be taken to ensure that the emails written do not contain any information that could be used to harm the Company, its customers, employees or shareholders.
If confidential information must be sent over the internet, secure (encrypted) emails must be used. ‘Highly Confidential Information’ related to the business must not be sent outside the Company via email.
In order to reduce the risk of customer information being exposed, if a customer sends an email that contains personal information, such information must be deleted from the reply message.

Emails must not be used for:

Sending or storing messages that might be considered offensive, derogatory or hostile;
Sending or storing messages that contain virus warnings or jokes (such warnings must be reported to the Information Security Management);
Engaging in communications or activities that might harm Aydem Enerji or any of its customers or shareholders;
Forwarding chain messages that contain protests, donations or statements that exploit people’s emotions (those who send such messages must be warned, and the Code of Ethics Consultant must be informed of the presence of such chain messages in the system);
Sending messages that are not business-related and are aimed at entertainment; containing game, sound or image attachments that may affect the system capacity negatively;
Chatting on messenger programs during working hours; sending emails and messages to the extent that the work is neglected.

Monitoring the Employee’s Use of Emails and Other Systems

Aydem Enerji reserves the right to monitor if the email, computer files or systems entrusted to employees are being used for the intended purpose.

The Company has the right to check and, when necessary, intervene and read all email communications. All kinds of document theft, contract theft, and unauthorized photo shootings, as well as any questions to employees with the aim of leaking information are considered security breaches. The personnel acknowledges this practice in advance. If the data/information security breach was made by an employee of the Company, disciplinary provisions shall apply for the relevant employee and the authorized person who committed negligence in that case. If it was made by an external person or organization, legal actions shall be taken if deemed necessary.

Within the scope of the ethical review and disciplinary proceedings, the Directorate of Internal Audit and Control is the only business unit that is authorized to review the device and software (notebook, external data storage device, mobile phone, tablet, email, Skype, SMS, etc.) entrusted to the employee by the Company. The Directorate of Internal Audit and Control may request the relevant records from the Directorate of Information Technologies in writing to review them. This authorization can never be transferred to another unit and the data cannot be shared with internal/external third parties. The Directorate of Internal Audit and Control is the sole holder of such authority as per the precedents by the Constitutional Court and the Supreme Court, as well as the Personal Data Protection Law (KVKK) and the related legislation, and the relevant articles of the Information Security Policy of Aydem Enerji.

Respect at the Workplace and Business Life

Behaving Respectfully and Thoughtfully in Our Relationships with Others

At Aydem Enerji, our main purpose is to approach our employees respectfully, thoughtfully and sympathetically, and to create an environment that will contribute to a complete communication at all levels. We encourage our employees to openly discuss business-related issues and offer solutions to them.

The common goal must be to improve the team spirit within the Company, and to protect and enhance the corporate identity. At the workplace, all employees are responsible for creating and maintaining an environment that complies with all the values stated in this manual.

Aydem Enerji provides job opportunities for people who add to the corporate diversity in terms of race, religion, nationality, gender, sexual orientation, marital status, age, seniority, family, etc. Our employees must embrace such diversity and maintain relationships with each other in compliance with the principles of mutual respect, fairness, kindness, honesty and equality.

Employees must not disturb each other in common areas (including the shuttles) designated to them. It is prohibited to place posters, scripts or notes and to sell products or services in these places except for those areas allowed by the management.

It is not acceptable for an employee to harass another employee directly, or indirectly through phone, email, etc. Harassment includes but is not limited to the following:

Using derogatory statements to define the members of a certain group;
Negative classifications, humiliating jokes, offensive statements;
Mocking pictures or caricatures that humiliate a certain group or person;
Derogatory statements or physical attacks that affect the relationships between employees by creating an uneasy and hostile working environment;
Physical or verbal behaviors that do not keep the distance required by the working environment; associating an employee’s sexual orientation with their promotions, performance reviews, collaborations with colleagues, etc. or threatening them;
All kinds of unwanted sexual advances, sexual offers, speeches and similar behaviors.

When an employee reports any harassment or inappropriate behavior at the workplace to the relevant management and/or the Code of Ethics Consultant, it is prohibited to blame and/or retaliate against them in any way. In addition, our managers must handle such cases with confidentiality.

In case of a harassment like above, or offensive, accusatory attitudes and behaviors, or a problem that negatively affects the labor force and performance within the Company, or in cases where an employee thinks that they are subjected to a similar behavior by their colleague, manager or a customer, the Code of Ethics Consultant and the Human Resources Management must be informed.

Our Principles on Harassment and Mobbing

We do not tolerate any kind of privacy violation through physical, sexual and/or emotional harassment towards our employees, or by our employees towards our shareholders we have a business relationship with, at the workplace or in any other place they visit for business purposes. Potential negative attitudes and behaviors against individuals who report such cases or help with the investigation of the same shall be considered violation of our code of ethics.

We do not tolerate systematic or planned behaviors that are aimed at causing someone to become disinclined to work, deteriorating their performance or making them resign in a scheme that would be considered mobbing.

Attitude/Behavior and Appearance

As Aydem Enerji employees, we must have a clean, nice and professional way of dressing in the working environment and be genial, attentive and respectful to everyone. With our behaviors and appearance, we must represent Aydem Enerji, a corporation of trust, in the best way possible. This principle is vital to improve customer relations and increase the reputation of the Company and must be strictly followed.

Creating team spirit in the Company, and protecting and improving the company image is a common goal that plays an important role at the workplace and in the personal life of each and every employee. We must have a balanced and consistent attitude in professional and financial terms in order to prevent potential negative effects on the work we do and/or the company image.

Also in our relationships outside the Company, we must show an equal level of respect to our existing and potential customers, shareholders and the communities we serve.

This requires offering services in a kind manner and complying with code of business ethics, as well as all applicable laws and regulations. As employees of a customer-oriented company, it is our responsibility to act in a manner that will leave good impressions about Aydem Enerji.

When performing our daily tasks, we must comply with the highest standards of integrity, and we must strive to do our work in the best way possible to reach the Company’s goals and objectives. We must use the time efficiently during working hours and make sure that our personal matters do not take too much time to avoid impeding the transactions of customers.

Workplace Hierarchy

Improvement of employees greatly helps Aydem Enerji reach its goals. Managers must manage their employees based on professional criteria, and provide them with equal development and reward opportunities based on their contribution to the Company’s success. Managers coordinating certain tasks or departments must use their specific authorities in a balanced and impartial manner, considering the personal dignity of the personnel. Our managers must avoid exploiting their positions and responsibilities for doing something/getting something done outside the scope of their authorities, regardless of the purpose. Our managers must continuously support the professional development of their employees.

Managers are responsible for offering and implementing management methods that will increase the value of the Company, provide maximum profit for the Company and protect employee rights in the long term, in compliance with the principles of honest and prudent management.

Employees must avoid behaviors that are against the working principles and ensure maximum collaboration with their managers.

As a general rule, our employees are responsible for following the orders given by their superiors. However, they are not obliged to follow the orders that may harm Aydem Enerji’s profitability, efficiency and reputation, or that are against the Company’s relevant principles and the legislation. If an employee believes that the orders are against the legal and/or internal regulations or harmful to the Company, they shall report such opinion to the manager of their superior who gave that order and the Code of Ethics Consultant. If an employee following an order believes that what they are doing as per the order is a crime explicitly stated in the relevant laws and regulations and/or that such order will cause loss to the Company, they must immediately report it to the Directorate of Internal Audit and Control.

Relationships between different levels of task must be regulated in line with the rules of mutual loyalty and respect required by the hierarchy, within the Company in a manner that respects the Company’s values and goals.

Kinship in Employment

Employees who have the following levels of kinship cannot be employed in such a way that they will directly report to the same manager in any department of the Company.

Spouse, mother, father and children, siblings, uncles, aunts and their spouses and children
Spouse’s mother, father, siblings, uncles, aunts and their spouses and children

All actions that cover the family members and relatives of employees are carried out by other employees who are not associated with such actions.

Compulsory Attendance

Our employees are responsible for complying with the working hours determined for their respective workplaces and using the personnel attendance control system (card reader, fingerprint access, etc.) when entering and leaving the workplace. It is obligatory for employees to be present at the workplace during working hours.

An employee who leaves their place of duty for any reason must report this to their immediate manager or to their nearest colleague so that they can report it to the said manager.

An employee who must be outside the company as per their job must inform their manager about the place they are going to and the time they will spend outside.

Sharing Information with Colleagues - Handover Obligation

An employee who is leaving their job temporarily or permanently cannot do so unless they hand over the money and other assets that can be used as money, as well as the documents, vehicles and tools they have had to keep and use. This principle also applies to those assigned to temporary duties.

If failure to do the handover causes loss to the Company, those who caused it shall be held responsible.

Equality of Opportunity/ Providing Equal Opportunities in Employment

Aydem Enerji aims to create a working environment where the talents and experiences of each individual are valued, diversity is respected, and each and every employee can express their thoughts and opinions.

Respecting diversity is not only the correct way of doing business but is also vital for success.

Aydem Enerji does not allow discrimination between employees. It ensures that all practices regarding the personnel are handled based on individual capabilities and qualities, regardless of race, religion, color, age, gender, national origin, sexual orientation, physical disabilities, seniority or other factors defined and protected under the law. These practices include but are not limited to recruitment, election, performance management, training, onboarding, transfers, promotions, disciplinary actions and termination of employment.

Scope and Rules of Implementation

The Code of Ethics and Working Principles of Aydem Enerji were released by the Board of Directors and are reviewed annually according to needs, changing conditions and current practices.

Violations of the Code of Ethics and Working Principles, and Possible Consequences

Our Code of Ethics and Working Principles are among the main contributors of our reputation and continued success in the sector. Violating these rules and principles may adversely affect our reputation and success in the sector. For this reason, unethical behaviors that are against our principle of honesty or acting outside the working principles requires ethical review or disciplinary investigation. All employees are obliged to comply with these rules.

Our employees have the obligation to fulfill their responsibilities according to the applicable written laws, regulations and legislations, as well as the general practices. When fulfilling their responsibilities or doing their daily tasks at the Company, employees can under no circumstances engage in an illegal activity or inform anyone this way.

Violating the laws, corporate principles or the code of ethics in any way such as refusing to collaborate in an investigation can be subject to ethical review or disciplinary investigation.

Roles and Responsibilities of Code of Ethics Consultants

A Code of Ethics Consultant is the top manager responsible for the human resources management at each company of Aydem Enerji. Code of Ethics Consultants are responsible for:

Offering guidance and consultancy to company employees about their questions and concerns on ethics;
Escalating to the Ethics Committee any ethical non-compliances at the company that could not be resolved or require ethical reviews or disciplinary investigations;
Contributing, as per the Ethics Committee’s request, to the resolution of internal ethical non-compliances they have been informed of;
Reporting the ethics questions and non-compliances, together with their results, to the Ethics Committee regularly or upon request;
Acting as the contact person for the ethical reviews and investigations requested by the Ethics Committee and supporting the reviews and investigations made by the Directorate of Internal Audit and Control;
Tracking and monitoring the efficiency of the ethics practices applied at the Company, and providing support in implementation.

Roles and Responsibilities of Managers

Managers at Aydem Enerji have additional responsibilities beyond those defined for employees in the Code of Ethics and Working Principles. Accordingly, managers are responsible for:

Ensuring that a corporate culture and working environment that support the code of ethics are created and maintained;
Leading by example in the implementation of the code of ethics, and training their employees on the code of ethics;
Encouraging their employees to submit their questions, complaints and reports on the code of ethics;
Guiding those who consult them on what to do, taking into account all the reports submitted and, where required, sending such reports to the Ethics Committee in the shortest time possible;
Ensuring that the business processes they supervise are structured in a manner that will minimize ethical risks, and adopting the methods and approaches required to ensure compliance with the code of ethics. Uyumsuzlukların Çözümlenmesi

Resolving Non-Compliances

Ethical non-compliances are resolved by the Ethics Committee of Aydem Enerji.

The Ethics Committee is comprised of the Chair of the Board of Directors, Human Resources Top Executive of the Group, and Legal Top Executive of the Group. The Ethics Committee assesses the ethical review and disciplinary investigation reports drawn up by the Directorate of Internal Audit and Control in order to evaluate violations. Ethics Committee’s functioning, decision-making processes, relationships with the Disciplinary Committees at the companies and reporting practices are detailed in the Disciplinary Practices Procedure.

Reporting Violations, and Working Principles of the Ethics Committee

The Ethics Committee carries out their operations as per the following principles:

It keeps confidential the reports and complaints, as well as the identity of those who have submitted those reports or complaints. It adopts a policy that prohibits retaliatory attitudes and behaviors against employees or persons who have reported an ethical violation.
It conducts reviews and investigations according to the rules of confidentiality.
It has the authority to directly ask the relevant unit for the information, documents and evidence associated with the review and investigation. It can review the information and the documents obtained only for the relevant investigation purpose.
The review and investigation process is written down in a report from the beginning. Information, evidence and documents are included in the report.
Notifications related to the review and investigation are immediately handled and a consequence is reached in the shortest time possible.
Decisions made by the Committee are implemented with immediate effect.
Relevant departments and authorities are informed about the consequence.
When fulfilling their duties during this process, the chair and members of the Committee act independently of and without being affected by the managers of the departments they work for and the organizational hierarchy. They cannot be forced or given suggestions on the subject matter.
The Committee, if it deems necessary, can consult an expert’s opinion and work with experts during the review or investigation process on the condition that measures are taken to avoid violating the principles of confidentiality.

For your questions and reports, you can use the contact channels below or directly contact the members of the Ethics Committee.

E-Mail : etik.gedizperakende@aydemenerji.com.tr

Tel : 0 (850) 575 0 575

Posta address: To the “Office of Ethics Committee” of İzmir given on the website of our Company

Procedure on Preventing Domestic Violence

1. OBJECTIVE

This Procedure was designed for Aydem Holding and the affiliated group companies (hereinafter referred to as “Gediz Perakende”) to raise awareness on Domestic Violence with a zero tolerance approach, and to create a work environment that shows this zero tolerance approach we adopt against all kinds of violence, and where our employees suffering from domestic violence can speak up safely and confidentially and get help and support.

We believe that domestic violence and abuse is a basic problem of inequality and a violation of human rights. In this regard, for our employees suffering from domestic abuse, we are offering an environment that supports equality and stands up to all kinds of violence, where such employees can talk in privacy and get support and help.

2.SCOPE

This Procedure was prepared to include all Gediz Perakende employees suffering from domestic violence, regardless of gender.

This document sets out the methods and practices to be followed in case of domestic abuse and covers Gediz Perakende group companies, manufacturing sites and subsidiaries; it is also a guiding document for contractors, suppliers and third parties.

Those who are not members of Gediz Perakende will also be covered by this Procedure if the party using violence is a member of Gediz Perakende.

3. RESPONSIBILITY

Gediz Equal Life Team: The team, together with the Group Directorate of Human Resources, is responsible for creating and updating the Procedure. It is also responsible for designing the projects required to raise awareness within the company, collaborate with relevant departments and go live.

Group Directorate of Human Resources: This Directorate, together with the Company’s Human Resources, Audit and Legal departments, is responsible for implementing and auditing the policies and rules in this Procedure, creating a safe environment for employees and managing the disciplinary processes where required.

Group Directorate of Internal Audits and Controls: This Directorate is responsible for reviewing the reports -in confidentiality- submitted by those within the company and by external parties that are not members of Gediz Perakende, and to transfer them to the Human Resources, Domestic Violence Measures and Support Committee to provide the support required for each case. It is also responsible for conducting ethical investigations and providing opinions for disciplinary actions where necessary.

Domestic Violence Measures and Support Committee: This Committee is responsible for coordinating the processes to review the applications submitted internally and externally in confidentiality and providing the support required for each case, as well as getting recommendations and conducting studies for developing and improving support mechanisms.

Group Directorate of Corporate Communications: This Directorate is responsible for conducting the communication processes required to raise awareness on domestic violence with the Gediz Equal Life perspective in and outside Gediz Perakende, and for taking the necessary steps to increase recognition of the projects among internal and external stakeholders.

Company Human Resources: This department is responsible for creating a safe work environment for employees according to the rules set out in the Procedure, and in cases where an employee requests support, it is also responsible for ensuring that said employee confidentially reaches the resources and facilities set out in the Procedure.

Gediz Academy: Together with the Gediz Equal Life Team, it is responsible for designing internal trainings, supporting internal trainers with ‘train the trainer’ sessions, taking and following the actions for ensuring that all Gediz Perakende employees attend and complete the trainings to ensure inclusiveness.

Employee Suffering from Domestic Violence: If they need support, they are responsible for knowing that they can confidentially report this to the human resources, workplace physician and/or the organizations stated in the Procedure.

3. DEFINITIONS

Domestic Violence: It covers all individuals that a person feels close to and calls ‘family’; all relationships covering the extended family in traditional terms, regardless of if there is a marriage bond or not, if the relationship is continuing or not, if the relationship is between spouses or parents-children or not, or if there is an extended family relationship or not. Violence is defined as all types of behaviors including threats, pressure and controlling, that cause physical, sexual, economic or psychological damage or suffering to a person. Therefore, as per both of the definitions above, all cases of violence that a person may be directly subject to or witness within these relationships are defined as “Domestic Violence”.

Domestic Violence Victim: A person subject to violent behavior in their close relationships.

Abuser: A person demonstrating violent behavior in their close relationships.

Witness: A person who has not directly been subject to violence but witnessed it.

Domestic Violence Measures and Support Committee: It is a committee that was created for the Prevention of Domestic Violence in Business Project, comprising of members who attended trainings on gender equality, domestic violence, definition of violence and approaches to violence. It is comprised of the representatives of the Legal, Audit, Business Unit and Corporate Communications departments under the leadership of the Group Directorate of Human Resources.

Applicant: Those who directly or indirectly suffered from domestic violence or witnessed it can apply. All employees can apply. However, those who are not members of Gediz Perakende can also apply if the party using violence is a member of Gediz Perakende.

Physical Violence: Acting against the will and approval of the other party in the relationship and doing things to damage their body parts; slapping, pushing, punching, pulling hair, tying, biting, dragging, injuring with a tool, kicking, stepping on, hurting with a cigarette, etc.

Verbal Violence: Yelling, mocking, blaming, criticizing in destructive manner, insulting, swearing, calling names, making accusations and allegations to reduce their self confidence and trust, etc.

Psychological Violence: Acting in a manner to damage the psychological state of the other party in the relationship; not talking to them, applying pressure, threatening with suicide, jealousy, restricting their behaviors and relationships, intimidating, scaring, hiding facts, keeping the children away, etc.

Economic Violence: Intervening in the other person’s economic activities, seizing their income, not assuming the expenses or responsibilities for children, not including the person in decisions that concern them as well, restrict their economic needs without any valid reason, not meeting personal or domestic needs, etc.

Sexual Violence: Forcing the other person to demonstrate sexual behaviors they do not want, touching sexual parts of the body in an unwanted manner/at unwanted times, forceful sexual intercourse, sexual harassment, using force during sexual intercourse, trivializing behaviors related to sexual orientation, forcing to have or not have children, cheating, forceful or child marriage, etc.

Digital Violence: Continuously sending messages, applying pressure to the person to send messages, call on mobile phone to check what they are doing, asking them to send location to see where they are, stalking their social media accounts, recording on hidden camera, taking pictures or videos of the person to use as a threat, etc.

Dating Violence: It is the case when a person is subject to physical, sexual or psychological violence by the person they are in a close relationship with.

Persistent Following: It is the case when a person follows another person unlawfully and with regular/repeated behaviors, harassing them with words and behaviors or using violence against them. In case of persistent following, the abuser makes the victim feel that they are in danger so that they get scared.

Cycle of Violence: Violence happening systematically may lead to a cycle of violence and apology. This may happen when the abuser apologizes to the victim for their violent behavior, makes them feel guilty, cuts off contact, promises to change their behaviors and then repeating the same violent behavior.

Gender: Socially constructed roles, behaviors, activities and characteristics that a society thinks are appropriate for women and men.

Gender-Based Violence: It is a type of violence aimed at a gender, applied because of that gender or disproportionally.

Signs of Violence: As violence is usually experienced in private life, it may not be easy to realize from outside. However, some behaviors of the victim may be warning signs that they are suffering from violence. Common signs are given below:

Physical signs: Apparent scars on body parts such as wrists and neck; bruising; apparently pulled-out hair; overly applied makeup that looks like it is done to cover scars; unnecessary or unseasonal accessories; weakness on muscles; limping; moving slowly and restlessly to prevent potential pain.

Behavioral signs: Depression; feeling of inadequacy and low self esteem; anger; continuous sadness; restlessness, fear; guilt; aggression; anxiety; communication disorder; hopelessness; fatigue; staying for a long time at the workplace outside required business hours; increased consumption of medicine or alcohol, etc.

Job performance signs: Showing up to work late; leaving work late; taking compassionate leaves frequently; mistakes and forgetfulness; failure to focus; not answering or hesitantly answering phone calls; problems of perception; feeling scared to leave the workplace building alone or to walk to the parking lot alone; spending too much time on matters not related to work; requesting leaves for various reasons and for durations that exceed normal leave durations.

4. CODES OF PRACTICE

In case of a request for help regarding domestic violence, Gediz Perakende will provide recommendations to its employee for guidance, for support services and for benefiting from relevant non-governmental organizations.

For all help requests for domestic violence, rights of the victim employee are protected, and the process is carried out with respect to the privacy of said victim and the employees under risk; information is never shared with third parties. It is only possible upon approval from the victim to inform the Group Directorate of Human Resources and/or relevant official bodies to ensure workplace safety.

Below are the channels that employees subject to domestic violence or other people subject to domestic violence by the Company’s employees can use. These channels are available for use by all employees.

External reporting channels:

Emergency line for fighting domestic violence: 0212 656 96 96 / 0549 656 96 96
183: Communication Center of the Ministry of Family, Labor and Social Services
155: Police
156: Gendarme
Emergency: 112
Bar: 444 26 18
Mor Çatı (Women’s Shelter Foundation): 0212 292 52 31-32
Federation of Women's Associations of Turkey: 0212 656 96 96 – 0549 656 96 96
KADES App
KAHDEM- Central Association for Legal Support for Women: kahdem@gmail.com

Internal reporting channels:

Domestic Violence Measures and Support Committee: aileicidestek@aydemenerji.com.tr
Gediz Perakende Ethics: etik.gedizperakende@aydemenerji.com.tr
Gediz Equal Life: esithayat@aydemenerji.com.tr
Gediz Perakende - Fighting Domestic Violence Lines: 0232 990 00 00

Psychological and legal consultancy services are available 24/7 and the line is operated under confidentiality terms by an independent company.

Workplace Physicians
Group Directorate of Human Resources
Human Resources Managers
Managers and Directors

Supporting Employees Suffering from Domestic Violence

For an employee whose legal procedures have started and/or who has reported this to the company, Gediz Perakende can make the relevant assessments and provide support for the following matters:

If requested by the victim, paid administrative leave of up to 10 days may be give to them -except for their annual leave- for the relevant medical examinations and legal proceedings, obtaining security and protection, finding a new house, receiving consultancy or health services or dealing with other relevant matters. It is possible to use this leave hourly, one day only or on multiple days up to 10 days in a calendar year. Requesting and using this additional leave will not affect the employee’s other leaves they have the right for or working conditions.
If requested by the employee suffering from domestic violence, flexible working conditions might be offered to them.
If the employee requests to see an expert psychologist, therapy support may be provided to them, informing them that no data will be processed by the company. For this, the employee can be directed to 24/7 psychological consultancy and guidance on the phone.
Employee support program: With the Fighting Domestic Violence Line, the employee can get limitless legal and psychological consultancy and four face-to-face psychological consultancy services.
If the employee subject to domestic violence requests, they can receive an advance payment/free additional payment amounting to one gross salary upper limit once in a year, due to the challenges they have faced.
At Gediz Perakende, it is ensured that the employee subject to domestic violence keeps being involved in performance review processes and benefiting from performance-based rewarding and benefits offered to all employees.
To mitigate the concerns that the employee may have regarding their performance, the criteria are reassessed upon agreement with their manager, and the performance goals and criteria to be applied for this employee are determined according to their current situation. Throughout this process, Gediz Perakende exercises due care to comply with the privacy of the employee and the principle of confidentiality.

Safety of the Employee Suffering from Domestic Violence

If an employee suffering from domestic violence makes a request, Gediz Perakende will take the necessary actions to ensure their safety with the aim to support protection of its employees against domestic violence.
Regarding these actions, the decision-making body is the Fighting Domestic Violence Committee and he Group Directorate of Human Resources.
If they deem appropriate, in addition to the actions stated below to ensure safety of the victim, they may decide to take different actions and/or not to take actions.
If possible, working hours and/or location of the victim may be changed
Their work phone number and/or e-mail address may be changed, and it may be prevented to reach them though the company’s phone line
If the victim is using a company car, the car and/or the license plate may be changed
If requested by the victim, a place will be reserved for their personal car on the company’s parking lot
It may be ensured that they do not work alone
They may be escorted to their vehicles or public transportation points
All employees who have a temporary or permanent protection order, where the workplace address is determined to be a protection area, must inform Human Resources and submit a copy of the petition and the court order. The victim must give the company the abuser’s picture or a description of their appearance, a description of their car and the license place, and all other information that the directorate may need to ensure workplace safety.
It is ensured that sub-employers take the necessary measures as well, and that especially the sub-employer providing security receives training on violence against women and that this topic is added to the safety plan. If any, a picture and license plate number of the car of the person using violence against a woman must be given to the security team and to those deemed appropriate by the victim.
Payment details and method for the victim’s salary and benefits may be rearranged for the benefit of the victim to prevent access by the abuser. Another account may be created, from which the victim can receive their salary.
Phone records or electronic messages of the abuser using violence against the victim may be kept.
Access to the victim via the company’s phone lines may be prevented.

Employees Who Use or Threaten to Use Domestic Violence

If an employee finds out that one of their colleagues is suffering from domestic violence upon statement by that person, they will be responsible for encouraging that colleague to consult to human resources, workplace physician and the organizations offering support for this matter.
It is strictly prohibited to contact the relevant units on behalf of the victim.
The victim may request support from any of the relevant units, if they wish to.

An Employee Who Found Out That Their Colleague is a Victim of Domestic Violence

Şirket içinde herhangi bir çalışma arkadaşının beyanı doğrultusunda aile içi şiddete maruz kaldığını öğrenmesi durumunda, iş arkadaşını şirket insan kaynakları, işyeri hekimi, bu konuyla ilgili destek veren kurumlarla görüşmeye teşvik etmekle sorumludur.
Şiddete maruz kalan kişi yerine ilgili birimlerle iletişime geçmek kesinlikle yasaktır.
Maruz kalan kendi istediği takdirde ilgili birimlerden kendisi destek talebinde bulunabilir.

Cases Where the Abuser and the Victim Work at the Same Company

If the abuser and the victim are working at the same company, necessary arrangements will be made to ensure that the abuser is not close to the victim. In this case, Gediz Perakende may anticipate the needs of the victim and change the location of the abuser.

Actions to be Taken to Raise Awareness Among All Company Employees Regarding Domestic Violence and to Prevent Violence:

Gediz Equal Life - Domestic Violence Awareness Trainings
Communication trainings designed specially for the Fighting Domestic Violence Committee
Trainings for Human Resources, Workplace Physicians and Line Managers to ensure they can recognize warning signs of domestic violence
Special trainings for the security personnel
Training as art of the orientation training
Training as part of the trainings for new managers
Educational video series
Seminars/Webinars domestic violence awareness
Web-based trainings
Awareness studies through notice boards
Mailing Studies
Company Newsletters
Brochures/Posters
Gediz Perakende mentions domestic violence in training programs related to other matters as well. For example, at Gediz Equal Life trainings that contain gender mainstreaming training sessions, it is aimed to raise awareness on violence and domestic violence.

5.CONTROL

5.1 Effect

This procedure shall come into effect upon approval from CEO; once it has come into effect, the previous procedures, notices and instructions shall be abolished.

5.2 Revision

This procedure shall be revised annually by the Gediz Equal Life team and the Group Directorate of the Holding’s Human Resources Department.

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