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Ethical Principles


  1. OBJECTIVE

Ender Pvc Yapı Elemanları San. ve Tic. A.Ş. defines its "Ethical Principles," which are principles and rules that all managers and employees must adhere to, in order to add financial value to its shareholders and increase its corporate value. With these rules, it aims to ensure that Ender Pvc’s managers and employees exhibit high standards of behavior, are aware of the corporate impact of their actions and attitudes, use the most appropriate methods, and display the highest quality behavior. The following Ethical Principles of Ender Pvc are expected to be followed by the Board of Directors, managers, and all employees.

  1. SCOPE

The Ethical Principles apply to all employees of Ender Pvc and its affiliated companies. It is important and mandatory for every employee within Ender Pvc to adhere to these principles. The application of these principles is the guarantee of the perfection that Ender Pvc seeks to achieve. The principles are broad and general in content, and provide the minimum standard.

  1. RESPONSIBILITY

Creating an environment compliant with ethical principles in our company is the responsibility of our managers. To this end, the members of the Board of Directors and our managers first accept the importance of the Ethical Principles and adhere to them. They set an example for other employees with their behavior and thoughts, adopting the placement and sustainability of these principles, especially in the units they are responsible for. They work towards embedding the company culture, familiarizing employees with the norms, values, and principles they must adhere to. They ensure an environment where employees can communicate openly regarding both company operations and ethical issues. In their behavior and decisions, they always demonstrate honesty and consistency, including in cases where conflicts of interest may arise, both currently and in the future, with personal relationships or financial and commercial interests. In case of known or suspected violations of the Ethical Principles, they report this matter to the Ethics Committee without delay.

Additionally, to support the application of Ender Pvc’s Ethical Principles, the members of the Board of Directors, the Group President, and the Human Resources Managers/Employees are responsible.

If there is any uncertainty about how to apply the principles in a specific situation, the issue should be referred to a superior manager.

Any employee of Ender Pvc who has questions or comments regarding the principles, whether related to a specific case or situations that may apply to current or future cases, must engage in internal communication within Ender Pvc.

  1. ETHICAL PRINCIPLES

Ethical principles are an important element both for the success of our company and for personal success. The ethical principles that our employees are required to follow are categorized under four main headings:

General Rules

Use of Company Resources

Relationships

Obligations towards the Company

These are presented in the following sections.

4.1. GENERAL RULES

4.1.1. Honesty

Accuracy and honesty are our primary values in all our business processes and relationships. We act with accuracy and honesty in our relations with employees and all stakeholders.

4.1.2. Respect for the Law

We comply with all legal regulations related to our activities. Employees are not allowed to engage in illegal activities under the assumption that they serve the company or personal interests. Accuracy and legal compliance are essential in financial and commercial records. If a legal doubt arises regarding a particular job, the matter is referred to the Ethics Committee, the company Group President, and the Legal Director.

4.1.3. Confidentiality

Confidential information is defined as information that belongs to the company and is unknown to third parties, which, if disclosed, could cause harm to the company and/or its stakeholders or provide benefits to others, including financial, strategic, technical, commercial, and personnel-related information, as well as subjects covered by confidentiality agreements with third parties. Our employees are expected to protect the confidential information mentioned above and use it only for company activities. Employees take care to protect the information belonging to Ender Pvc and all its stakeholders. Employees share this information only within authorized limits with relevant individuals. They are not allowed to use this information for personal gain, including trading stocks based on insider information (insider trading). Upon leaving the company, employees must not share any confidential information with third parties. During their employment, they are required to return all confidential documents or electronic copies to the company. All official statements are announced to investors, partners, and the public through the units designated by Ender Pvc, in a manner that is complete, simultaneous, and comprehensible, in accordance with the principle of equality.

4.1.4. Personal Securities Investments

Our employees cannot make personal investments in companies whose stocks or other investment instruments may create a conflict of interest with their responsibilities at the company. It is prohibited for individuals who may have access to undisclosed information to use such information for personal or third-party gain (insider trading). Insider trading may be performed by the Chairman and members of the Board of Directors, executives (managers and above), auditors, and others who may be in a position to obtain information due to their roles and relationships. These individuals can only buy and sell shares of Ender Pvc companies using public information for investment purposes, with the restriction that investments held for more than three months are considered long-term investments. Ender Pvc employees other than these individuals can freely buy and sell shares without any time limitations, provided they use public information. The same restrictions apply to the employees' spouses and children; their transactions are considered as if performed by the employee.

4.2. USE OF COMPANY RESOURCES

Maximum care is given in the use of all financial and non-financial resources of the company. These resources cannot be used for personal purposes such as expenditure, gifts, donations, and political aid.

4.2.1. Fixed Assets and Stationery

Stationery, printed materials, and all company assets can only be used for company-related work and cannot be taken outside the company. Saving principles are followed in their use within the company. Employees leaving their positions must hand over any assets, documents, or equipment assigned to them by the company in accordance with a protocol.

4.2.2. Communication Tools

Email is used solely for business-related communication, and employees are expected not to use it for personal reasons. Whenever possible, email should be used instead of phone calls. Fax, photocopying, internet, and similar tools should not be used for personal business.

4.2.3. Company Vehicles

Employees provided with company vehicles must use them with due care and responsibility. They will pay for any traffic fines themselves and will not request payment from the company for damages resulting from personal faults.

4.2.4. Workspaces

In company buildings, no goods or services can be bought or sold outside of business activities. Confidential documents or materials cannot be left on desks or in the open outside of working hours. The following rules apply to the use of our office spaces:

Posters or handwritten notes cannot be hung.

No political or political campaign activities can take place, nor can funds be collected for them.

Publications that violate laws or company policies should not be distributed.

Alcohol, drugs, and weapons are prohibited in the workplace.

Employees must not leave confidential and critical documents unattended on desks or in cabinets, either during or after working hours.

Workspaces should be kept organized and tidy.

Gambling activities are prohibited.

4.2.5. Representation Expenses

Representation expenses are used for customer and business meetings. These expenses are only used within their relevant areas, and transitions between spending categories are not allowed.

4.2.6. Giving Gifts and Donations on Behalf of the Company

In accordance with the principles set by the company management, gifts that align with company business objectives, comply with the applicable laws, and would not embarrass Ender Pvc if made public, can be given on behalf of the company. Gifts and promotional materials given to third parties in business relationships are approved by senior management, and no additional permission is required for their distribution.

4.2.7. Time Management

Time is one of the most valuable resources for the company. Our employees make good use of their time and do not allocate personal time during work hours. Managers do not assign personal tasks to employees. The effectiveness of the time allocated for meetings is the responsibility of the meeting organizer, and it is essential that all participants come prepared. All participants must adhere to the start and end times of the meeting.

4.3. RELATIONSHIPS

4.3.1. Commercial Relationships