CORPORATE SOCIAL RESPONSIBILITY and ETHICAL POLICY

As Disa Automotive;

We consider adherence to local and international business ethics principles as a prerequisite in all our business processes and relationships, and we see it as the cornerstone of our corporate culture. Our Corporate Social Responsibility and Ethics Policy encompasses the set of ethical principles we have established to guide our work life.

1. COMPLIANCE WITH LAWS

We fully comply with all laws and regulations. We follow new laws, regulations, and legislation closely. All our activities are carried out based on legal regulations, the main contract, internal regulations, and corporate policies. No off-the-record activities are conducted. The accuracy and consistency of business records are essential.

2. RESPONSIBILITY

All our employees fulfill their responsibilities to protect and develop the corporate image and reputation. They ensure that their personal behavior remains within legal and general moral rules. As Disa Automotive employees, we are all responsible for adhering to our ethical policy, all laws and regulations, and all instructions, procedures, and regulations prepared by our company.

3. HONESTY, TRUST, AND EQUALITY

We communicate openly and honestly. Principles of honesty, trust, consistency, professionalism, and respect for mutual interests are observed with all customers, suppliers, and individuals or institutions we have business relations with. We treat each other equally and fairly. Mutual respect, trust, and cooperation among employees are essential. We act with our minds, aware of the importance of our work and our responsibility for trust, not with our emotions.

4. CONFIDENTIALITY

We protect the confidential information of each other, our institution, our suppliers, our customers, and all our business partners. We keep all confidential and trade secret information, personal information of our employees, and all information belonging to our business partners confidential against third parties.

5. CUSTOMERS

We communicate with our customers consistently, fairly, carefully, sensitively, and always promptly. Superior quality is aimed for in all products supplied or produced and all services provided; customer needs and expectations are fully met.

6. SUPPLIERS

We evaluate our suppliers fairly and equally. We do not exchange gifts. We are respectful and open in our relationships with our suppliers and always behave courteously. We clearly and in detail define the requested products and services; we expect our suppliers to work in compliance with defined working conditions through specifications, instructions, technical drawings, and contracts.

7. COMPETITORS

We compete legally and fairly. We do not engage in behaviors that restrict free competition, do not disparage any institution or individual, and do not engage in misleading advertising.

8. COLLEAGUES

We always treat each other openly, fairly, and respectfully. We develop trust-based, helpful, sharing, and honest relationships. Mutual friendship, respect, trust, and cooperation among employees are essential.

9. PREVENTION OF DISCRIMINATION

No discrimination is made based on race, color, age, gender, disability, pregnancy, religion, marital status, union membership, or political beliefs in practices such as wages, promotions, rewards, training, hiring, and employment among our employees, job candidates, customers, suppliers, and business partners.

10. PRODUCTS AND MEASURES AGAINST COUNTERFEIT PRODUCTS

We always maintain the highest value for the safety, reliability, and quality of our products. Superior quality is targeted in services and products; customer needs and expectations are fully met. We never compromise on quality, regardless of cost.

Our company plans, implements, and controls processes suitable for the organization and the product to prevent the use of counterfeit or suspected counterfeit parts and to prevent their presence in the products delivered to customers. We take all measures to prevent counterfeit parts in our supply chain. We expect our suppliers to manage the risks of counterfeit parts and take necessary measures in this regard.

11. INTELLECTUAL PROPERTY RIGHTS

We protect and respect all intellectual property rights and comply with international standards and laws in this area. We ensure the legitimate use of intellectual property rights and avoid misuse to prevent damage to intellectual property rights.

12. INTERNATIONAL SANCTIONS AND ECONOMIC POLICIES

We fully comply with international sanctions and the economic policies of different countries with which we trade domestically and internationally, adhering to relevant legislation and regulations.

13. USE OF RESOURCES

We act with maximum care in company expenses, with an awareness of savings and cost.

14. PREVENTION OF BRIBERY, CONFLICTS OF INTEREST, VIOLATIONS, AND RETALIATION

We expect all our employees to avoid situations that may create conflicts between company interests and personal interests. We adopt the principles of transparency and honesty to prevent conflicts of interest. No retaliation (including but not limited to discrimination, suspension, loss of rights, threats, or harassment) will be made against employees who report a violation or suspicion in good faith and honestly, or who seek information about our Ethical Policy. Even if it cannot be proven that there was illegal behavior or a violation of a rule as a result of the reporting of reasonable or justified concerns, no action can be taken against the whistleblower.

Our company adopts transparency and accountability in the execution and management of activities, including having effective processes and procedures to proactively prevent unethical behaviors such as bribery, corruption, conflicts of interest, facilitation payments, unfair competition, and abuse of authority with our suppliers and customers. We expect all our business partners to act sensitively in this regard.

15. CHILD LABOR, MODERN SLAVERY, AND FORCED LABOR

Our company is strongly opposed to child labor, which causes physical and psychological harm to children and deprives them of their right to education. We comply with all legal regulations to prevent child labor and determine the working age according to relevant laws and regulations. When employing intern young workers, we take all necessary measures to protect their health and safety.

Our company is against all forms of forced labor, defined as working involuntarily and under threat. We ensure that all our employees work of their own free will and enjoy their work. No illegal immigrant workers are employed within our company.

16. WORKING HOURS AND WAGES

In our company, we comply with the legal working hours and the maximum weekly working hours. We emphasize that employees take regular breaks, leaves, and maintain a productive work-life balance. In case of overtime, we obtain employees' consent and pay overtime wages in accordance with the law. We respect employees' rest and holiday rights.

The wage determination process includes all wages, including social benefits, calculated according to applicable laws and regulations and the provisions of the current collective bargaining agreement.

17. LAND, FOREST, AND WATER RIGHTS AND FORCED EVICTIONS

We protect and respect land, forest, and water rights and emphasize the sustainable use and protection of these resources for the health of ecosystems. We ensure that our company's activities do not participate in any way in the crime of forcibly displacing individuals from their lands. Additionally, we establish sustainable environmental practices with the affected communities to address potential complaints and find mutually beneficial solutions.

18. USE OF PRIVATE SECURITY AND PUBLIC SECURITY FORCES

We take measures to ensure that our security services operate respectfully to human rights and ensure that legal sanctions are consistent with international norms and standards. Security personnel (both employed and contracted) are trained and independently assessed regarding human rights standards and security procedures for complaints. We provide all requested information to public security forces within the scope of relevant laws. At the same time, we exercise the necessary diligence to ensure that no benefit is derived from the information provided to us.

To reduce the risk of harm to staff, take necessary precautions for employees working in risky areas, and eliminate the risk of exposure to physical and verbal violence, we immediately communicate any potential negative or inappropriate situation to our supervisors through the communication system or verbally at the time of the incident.

 

For any violations, notifications, or communication, Disa Automotive Ethics Committee can be reached at the email address: etik@disaotomotiv.com.

 

Document no: POL-002-01

Last revision date: 29.07.2024