Code of Business Ethics

CODE OF BUSINESS ETHICS
1.1. Our Code of Business Ethics

1.1.1. Confidentiality
Private and confidential information includes information that might lead to a competitive disadvantage of Bossa Ticaret ve Sanayi İşletmeleri T.A.Ş., trade secrets, financial and other information that has not been publicly disclosed, employee personal information, and information within the framework of "confidentiality agreements" enacted with third parties.
As employees of Bossa Ticaret ve Sanayi İşletmeleri T.A.Ş., we give utmost importance to protecting the privacy of our customers, employees and other associated individuals and companies and the confidentiality of their information. We protect confidential information regarding the activities of our company, use this information only for the purposes of Bossa Ticaret ve Sanayi İşletmeleri T.A.Ş., and share this information only with relevant authorised parties.
We strictly forbid insider trading, or gaining any financial or commercial interest, including trading stocks through disclosing confidential information belonging to Bossa Ticaret ve Sanayi İşletmeleri T.A.Ş.. When ending our employment with the company, we do not take with us confidential documents, projects, regulations, etc. that were confined to us due to our position.

1.1.2. Integrity
Integrity and honesty are our core values in all our business processes and interactions. We act in integrity and honesty in all our relations with the employees and stakeholders.

1.1.3. Conflict of Interest
As Bossa employees, we take responsibility to avoid situations and relationships that involve conflict of interest. We do not use our present position to obtain any benefits personally or through our families and relatives, from people and companies with whom we have business relations. We do not engage ourselves in any business activity aimed to gain personal financial benefit outside Bossa Ticaret ve Sanayi İşletmeleri T.A.Ş.. We refrain from using the name of company and the power of Bossa identity to gain personal benefit.
In cases of potential conflicts of interest, when we believe that interests of the relevant parties may be safely protected by legal and ethical methods, we adopt these methods. When in doubt, we consult our manager or the Human Resources Department.

1.1.4. Our Responsibilities
In addition to our legal responsibilities, we give utmost importance to fulfil the following responsibilities vis-a-vis our customers, employees, stakeholders, suppliers and business partners, competitors, the community, humanity, and to the name of Bossa.

1.1.4.1. Our Legal Responsibilities
We execute all our domestic and international activities and procedures within the framework of the laws of the Republic of Turkey and international laws; and we submit all required information to regulatory authorities and institutions in a correct, complete, clear and timely manner.
In executing all activities and procedures, we do not expect any benefit from, and keep an equal distance to all public institutions and organizations, administrative bodies, non-governmental organizations, and political parties; and we fulfil our liabilities with a sense of responsibility.

1.1.4.2. Our Responsibilities Towards Our Customers
We adopt an approach which is focused on customer satisfaction and proactive in responding to customers' needs and demands in an appropriate and timely manner. We deliver our services on time and under the promised conditions; we approach our customers with respect, honour, fairness, equality, and courtesy.

1.1.4.3. Our Responsibilities Towards Our Employees
We enable our employees to use their personal rights fully and correctly. We approach employees with honesty and fairness; and ensure a non-discriminatory, safe, and healthy working environment. We undertake the necessary efforts to enable personal development of our employees; with a social awareness support them in volunteering for appropriate social and community activities; and respect and assure the balance between their private and professional lives.

1.1.4.4. Our Responsibilities Towards Our Partners
Dedicating prime importance to the continuity of Bossa, and in line with our goal to create value for our partners, we avoid taking on unnecessary or unmanageable risks, and strive for sustainable profitability. We act with financial discipline and accountability, and manage our company's resources, assets and our professional work time with a sense of efficiency and economy. We work to enhance our competitive power, and to invest in areas with growth potential and which offer the highest return on allocated resources. We give timely, correct, complete, and clear information on our financial statements, strategies, investments and risk profile to the public and to our shareholders.

1.1.4.5. Our Responsibilities Towards Our Suppliers and Business Partners
We act respectfully and fairly as expected from a good customer, and ensure to fulfil our liabilities on time. We carefully protect the confidential information pertaining to the persons, organizations and our business partners.

1.1.4.6. Our Responsibilities Towards Our Competitors
We compete effectively, only in areas that are legal and ethical, and avoid unfair competition.
We support all efforts to construct a competitive structure targeted within the society.

1.1.4.7. Our Responsibilities Towards the Community, Society and Humanity
We care about democracy, human rights, protection of environment education and charities, disposal of crime and corruption. We act sensitively to social events in conscious to be a good citizen, try to join nonprofit organization, non goverment organization. We act sensitively to tradition and culture in Turkey and other countries.
Preservation of democracy, human rights, and conservation of the environment; education and charity activities, eradication of crimes and corruption is of utmost importance to us. We pioneer in social affairs with an awareness of good citizenship and responsiveness; we try to play a role in non-governmental organizations, in services and activities for the benefit of the society and public. We act in a responsive and sensitive manner in Turkey and towards the customs and culture of those countries where we undertake international projects.

1.1.4.8. Our Responsibilities Concerning the Name "BOSSA"
Our business partners, customers, and other stakeholders trust us due to our professional competence and integrity. We strive to keep our reputation at the highest level.
We offer our services within the framework of company policies, professional standards, our commitments, and ethical codes; and we ensure to fulfil our liabilities.
We offer services in areas where we believe we are or will be professionally competent; and we seek to work with customers, business partners, and employees demonstrate integrity and legitimacy. We do not collaborate with those impairing social ethics, and damaging the environment or public health.
We do not express our personal opinions, and only communicate our company's view in public, and in areas where we are perceived as representing our company.
When faced with complicated situations that may jeopardize Bossa Ticaret ve Sanayi İşletmeleri T.A.Ş., we consult first with the relevant personnel, following the appropriate technical and administrative consulting procedures.

1.2. Policies Supporting Code of Business Ethics

1.2.1. Conflict of Interest Policy
Employees of Bossa are required to avoid situations and relationships that involve actual or possible conflict of interest. Employees are required to assume the primary responsibility for avoiding the use of Bossa resources, name, identity and power for personal benefit and keeping away from situations that might have a negative affect on the organization's reputation and image.

1.2.2. Policy of Accept and Give a Present
Bossa employees are prohibited to receive and/or give any kind of benefits or gifts, with or without an economic value, that influence or might influence their and/or a third party's impartiality, performance, and decision-making while carrying out their duties.

1.2.3. Policy of Confidential Information Protection
Information is one of the most important asset for realizing vision of company. In this direction, efficient usage,sharing and provide confidentiality, integrity and accessibleness of information is joint responsibility. Coordination between managment systems and processes is vital to obtain maksimum benefit.
Information is among the most important assets that Bossa will use in realizing its vision. Therefore, effective use of information, sharing it appropriately, and preserving its confidentiality, integrity, and accessibility are the joint responsibility of all our companies and employees. The compatibility of the management systems established and processes implemented to manage information and its confidentially is very important in maximizing the benefit that the company shall receive.

1.2.4. Establishing and Preserving a Fair Working Environment Policy
Bossa considers the establishment and preservation of a fair working environment for the employees as an important priority. Through establishing a fair, healthy, and safe work environment in which employees are respected and all relevant laws and regulations are complied with, the intent is to improve and increase employee performance, development, and commitment.

1.3. Responsibilities of Employees
Bossa Code of Business Ethics and its relevant policies and procedures establish the ethical codes on how we should act and how we should do our jobs in detail. It is the primary responsibility of all employees to abide by these codes. Hence, all employees of Bossa have the responsibility to;
Act in accordance with laws and regulations under all circumstances;
Read the Bossa Code of Business Ethics, learn, understand, internalize, and act in accordance with the codes, principles, and values therein;
Learn the general and business-specific policies and procedures valid for the company;
Consult their manager or Human Resources about potential violations concerning self or others.

1.4. Responsibilities of Managers
Bossa managers have additional responsibilities except employees who are as a part of ethic rules. Accordingly managers;
Providing creation and contiunity of corporate culture and work environment that support ethic rules,
Lead by example to implementation of ethic rules and educate the employees about ethic rules,
Supporting the employees to notify questios and complains,
Responsible to decrease risks related to work process and implementation of required method and approachment to provide adaptation of ethic rules.

Bossa managers have additional responsibilities, further to those defined for employees within the framework of Bossa Code of Business Ethics. Accordingly, it is the managers' responsibility to;
Create and preserve a company culture and working environment that promotes the ethics codes,
Be a role model in practicing the ethics codes; educate their personnel on the ethics codes,
Support their employees in expressing their questions and in filing their complaints/notifications concerning the ethics codes,
Structure all work processes under his/her responsibility in a way as to minimize ethical risks and implement necessary methods and approaches to ensure compliance with the ethics codes.