Our policies
Quality Policy
1 PURPOSE
1.1. The purpose of the Quality Policy (hereinafter referred to as the “Policy”) is to determine and define the general principles and scope of application to be followed in the quality management processes of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“),
1.2. To ensure that the necessary actions are taken for the implementation of legislation, national / international standards and systems related to quality management and compliance with the Company's sustainability strategies.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Employee Refers to company managers and employees.
Quality Management System: The system established by the company to continuously improve and control the quality of its products or services.
Customer Satisfaction: Customers' satisfaction with the expectations they fulfil from a product or service.
Quality Performance: Performance measures that evaluate how well the company's products or services meet established quality standards.
3 SCOPE
This is politics;
Members of the Board of Directors of the Company,
Company managers and employees,
Companies and their employees from which goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 DUTIES AND RESPONSIBILITIES
4.1. Board of Directors
4.1.1. The Board of Directors is responsible for overseeing the formulation, implementation and updating of the Policy.
4.2. Quality Department
4.2.1 The Quality Department is responsible for the creation, implementation and updating of the Policy on behalf of the Board of Directors.
4.3 Employees
4.3.1 Company employees are obliged to act in accordance with the principles contained in the policy and in no case can they be forced to act contrary to the Policy. Employees are obliged to report all behaviours and practices contrary to this policy to their managers.
4.3.2 Managers are responsible for the correct application of the principles in the policy by the employees, subcontractors and their employees and business partners for whom they are responsible.
5 APPLICATION
1. The company implements the requirements of ISO 9001 Quality Management System, ISO 45001 Occupational Health and Safety Management Systems, ISO 14001 Environmental Management System and ISO 27001 Information Security Management System.
2. The company adapts and responds to expectations and demands in our processes, products and services, focusing on the customer experience.
3. The company always provides services and products in accordance with customer requirements and increases customer satisfaction.
4. The company serves its customers in accordance with the motto “QUALITY AND TIMELY PRODUCTION”.
5. The Company takes into account and supports the feedback and opinions of its employees and all related parties for the development of the Quality Management System and processes.
6. The company instils the understanding of quality in its employees and ensures continuous quality in production.
7. The company provides the resources needed for the Quality Management System.
8. The Company takes responsibility for the sustainability and effectiveness of the Quality Management System.
9. The Company implements the Quality Management System by supporting it with procedures and ensures its follow-up.
10. The Company encourages the participation of its employees and all relevant parties through training and development activities and strengthens the quality culture.
11. The Company provides training to ensure that all employees are aware of their individual and corporate responsibilities.
12. The Company follows the requirements and developments in the sector and leads by complying with local and international legislation obligations.
13. In the rapidly globalising world market, the Company uses the most advanced technology and ensures efficiency and continuous improvement in production.
14. The Company continuously improves itself within the scope of national and international laws, regulations and standards.
15. The Company sets targets for monitoring, measuring and auditing its quality performance, also with reference to sustainability targets, and achieves the relevant targets by planning for the targets.
16. The Company continuously improves the quality of its products and services in line with customer requirements, responds to demands in a timely, complete and accurate manner, and delivers performance above the expectations of its customers.
6 CONTACT
6.1. The Quality Policy has been announced to the Company's employees and is continuously and easily accessible through the corporate website.
6.2. The Company organises trainings to raise awareness of employees on environmental issues.
7 RUNNABILITY
This Quality Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Quality Policy will remain valid and in force until a new announcement is made.
8 SUPPORTING DOCUMENTS
EN-PL-017 SUSTAINABILITY POLICY
Environmental Policy
1 PURPOSE
1.1. The purpose of the Environmental Policy (hereinafter referred to as the “Policy”) is to determine and define the general principles and scope of application to be followed in the environmental management processes of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“),
1.2. To ensure that the necessary actions are taken for the implementation of legislation, national / international standards and systems related to environmental management and compliance with the Company's sustainability strategies.
1.3 The Company recognises continuous improvement of its environmental management by regularly measuring the environmental impact of all its activities, investments and operations in the supply chain, and full compliance with local laws and other relevant obligations as the basis of its Environmental Policy. Recognising its competitive power in the steel industry, the Company assumes the responsibility of keeping the environment clean and protecting the environment in which it operates and works. Accordingly, it aims to carry out its activities in a safe and environmentally friendly manner, taking into account legal requirements.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Employee Refers to company managers and employees.
Greenhouse Gas Emissions: It refers to the release of gases such as Carbon Dioxide (CO2), Methane (CH4) and Nitrous Oxide (N2O) into the atmosphere, which cause the sun's rays reflected from the Earth to be retained in the atmosphere and cause the Earth to warm up.
Net Zero: Refers to the balance between the amount of greenhouse gas emissions produced by an organisation, community or country and the amount compensated or absorbed.
Waste Hierarchy: Refers to the order of priority of all waste management steps (Prevention, Reduction, Reuse, Recycling, Recovery and Disposal).
Circular Economy: Refers to a model that aims to preserve the value of materials and resources for as long as possible by returning them to the product cycle at the end of their use while minimising waste generation.
Zero Waste: Refers to the waste prevention approach that includes preventing waste, using resources more efficiently, reducing the amount of waste generated, establishing an effective collection system, and recycling waste.
Supply Chain: It refers to the whole system of companies, people, technology, activities and resources that cover the movement of a product or service from the supplier to the customer and within this process.
3 SCOPE
This is politics;
Members of the Board of Directors of the Company,
Company managers and employees,
Stakeholders from whom goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 DUTIES AND RESPONSIBILITIES
4.1. Board of Directors
4.1.1. The Board of Directors is responsible for overseeing the formulation, implementation and updating of the Policy.
4.2. Environment Department
4.2.1. The Environment Department is responsible for the formulation, implementation and updating of the Policy on behalf of the Board of Directors.
4.2.2. The Environment Department is responsible for monitoring the Company's environmental performance, targets and the projects created to achieve these targets.
4.4. Employees
4.4.1. It is responsible for ensuring compliance with the policies determined by the Board of Directors, working in compliance with internal and external legislation and notifying via e-mail in case of any behaviour, attitude, transaction, action, decision, activity or practice contrary to the Policy.
5 APPLICATION PRINCIPLES
5.1. On climate change:
Meets the requirements of the relevant Environmental legislation ISO 14001 Environmental Management Systems and exceeds these legal requirements with the standards it creates and implements when necessary. Ensures continuous improvement in environmental performance and prevents environmental pollution sequentially in accordance with the waste hierarchy.
In order to minimise its environmental impact, performance indicators, especially emission reduction targets, are determined in line with the sustainability strategy, Sustainable Development Goals and local plans.
It continuously improves the Environmental Management System in line with the determined targets, protects the environment and develops its employees by providing them with awareness raising trainings on environmental awareness.
Organises awareness activities, trainings and seminars for its employees and all related parties regarding the protection of the environment, reduction of the use of natural resources and compliance with environmental rules.
It aims to ensure the commitment and responsibility of employees in environmental performance through trainings.
In order to combat climate change, it regularly calculates energy consumption and emissions and takes measures for energy efficiency and emission reduction.
Improves water management performance and reduces water consumption and wastewater.
It adopts zero waste principles, minimises waste generation and actively works for circularity.
Develops and implements circular economy solutions including waste prevention, reduction, reuse, recycling, recycling, recovery and disposal in accordance with the waste hierarchy in all its activities with a Zero Waste approach. It primarily separates unavoidable wastes at the source, recycles them or disposes of them with the most appropriate methods.
Ensures the disposal or recycling of wastes resulting from production and activities in accordance with legal requirements, minimises waste, prevents pollution at source, reduces greenhouse gases and attaches importance to biodiversity risks and opportunities. Improves resource efficiency.
Carries out activities for the protection and development of the ecosystem, habitat and biodiversity in the activity areas.
It reduces and prevents air, water and soil pollution, leaks and spills, noise as much as possible, uses natural resources in a controlled manner, develops protection methods and identifies and reduces risks for emergencies.
Carries out the operations in the production facilities in a safe, environmentally friendly manner and in accordance with the social conditions in the environment and the requirements of its employees.
Respects nature and living things for a clean environment.
It aims to include the best available, environmentally friendly and energy-efficient production techniques and technologies to achieve its goals.
Determines whether it meets the necessary environmental conditions in accordance with the life cycle principle in product-service purchases with significant environmental dimensions.
In order for the Environmental Management System to be perceived correctly, it ensures that it is based on the necessary and sufficient documentation, implementation and continuity.
Maintains effective communication with its stakeholders and keeps its efforts on environmental and social improvement alive.
In order to reach international standards in its activities, it complies with the legal regulations, standards, directives and rules of the institutions to which it is affiliated.
Makes its policy accessible to the public and third parties.
6 CONTACT
6.1. The Environmental Policy has been announced to the Company's employees and is constantly and easily accessible through the corporate website.
6.2. The Company organises trainings to raise awareness of employees on environmental issues.
7 ENFORCEMENT
This Environmental Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Environmental Policy will remain valid and in force until a new announcement is made.
8 SUPPORTING DOCUMENTS
EN-PL-017 SUSTAINABILITY POLICY
EN-PL-014 SUSTAINABLE SUPPLY CHAIN POLICY
OHS Policy
1 PURPOSE
1.1. The purpose of the Occupational Health and Safety Policy (hereinafter referred to as the “Policy”) is to determine and define the general principles and scope of application to be followed in the occupational health and safety management processes of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“),
1.2. To ensure that the necessary actions are taken for the implementation of legislation, national / international standards and systems related to Occupational Health and Safety management and compliance with the Company's sustainability strategies.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Employee Refers to company managers and employees.
Occupational Health and Safety (OHS): It includes measures aimed at protecting the health and safety of employees in workplaces.
WORK Accidents: Events that occur in workplaces and harm the health or safety of employees.
Near Miss: Refers to situations that are narrowly escaped from work accidents or dangerous situations.
Occupational Diseases: Health problems or diseases associated with a specific occupation or job.
OHS Risks: Potential hazards present in workplaces and the risks that these hazards may pose to employees.
3 SCOPE
This is politics;
Members of the Board of Directors of the Company,
Company managers and employees,
Companies and their employees from which goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 DUTIES AND RESPONSIBILITIES
4.1 Board of Directors
4.1.1 The Board of Directors is responsible for the formulation, implementation and updating of the Policy.
4.1.2 The Board of Directors is responsible for the supervision of the effective operation of the OHS and Environment Department in accordance with the principles and guidelines set forth in the Policy.
4.2 OHS and Environment Department
4.2.1 The OHS and Environment Department is responsible for the formulation, implementation and updating of the Policy on behalf of the Board of Directors.
4.3 Employees
4.3.1 Company employees are obliged to act in accordance with the principles contained in the policy and in no case can they be forced to act contrary to the Policy. Employees are obliged to report all behaviours and practices contrary to this policy to their managers.
4.3.2 Managers are responsible for the correct application of the principles in the policy by the employees, subcontractors and their employees and business partners for whom they are responsible.
5 APPLICATION
1. The company implements the ISO 45001 Occupational Health and Safety System and ensures the continuous improvement of its systems by periodically reviewing and monitoring performance.
2. The Company complies with local and international legislative obligations.
3. The company fully meets the needs of current and future customers, meets legal and other requirements, and works in a continuously developing manner with the principle of efficient resource utilisation.
4. The Company manages the hazards that may arise due to its operations in the following order;
- Destroying the danger
- Substitution
- Taking engineering precautions
- Taking managerial measures
- Do not use personal protective equipment.”
5. The company, together with its employees and employee representatives, provides a healthy and safe working environment by identifying potential hazards and risks in advance.
6. The company encourages innovation and suggestions in the working environment, continuously improves product technology by considering OHS factors, and prevents accidents, near misses and occupational diseases with advanced safety measures.
7. The company identifies risks, eliminates hazards and reduces OHS risks with the participation and support of employees/representatives and relevant units and creates a healthy and safe working environment.
8. The company informs employees and stakeholders about the company's management systems and policies, especially occupational health and safety, systematically increases the qualifications of employees at all levels through training and awareness raising, encourages creative initiative and awareness, and ensures that they develop personal responsibility in occupational health and safety.
9. The Company ensures that its visitors, suppliers and employees of the company from which it purchases services comply with OHS rules at all levels and checks compliance with legal legislation in order to fulfil them effectively.
10. The company takes corrective, preventive and remedial actions with the goal of zero occupational accidents.
11. With the support of its management, the company increases its occupational health and safety performance by following the developments in the sector and in the world.
12. The Company continuously improves all processes by reducing Occupational Health and Safety risks to acceptable risk levels.
13. The Company sets targets for monitoring, measuring and auditing the Occupational Health and Safety performance in line with the sustainability targets, plans for the targets and achieves the relevant targets.
14. The Company provides information, human resources, technology and financial resources to ensure the continuity of the Occupational Health and Safety System.
6 RUNNABILITY
This Occupational Health and Safety Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Information Security Policy will remain valid and in force until a new announcement is made.
7 SUPPORTING DOCUMENTS
EN-PL-009 HUMAN RESOURCES POLICY
EN-PL-011 QUALITY POLICY
EN-PL-017 SUSTAINABILITY POLICY
Energy Policy
1 PURPOSE
1.1. The purpose of the Energy Policy (hereinafter referred to as the “Policy”) is to promote the effective and efficient use of energy resources of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“), reduce energy consumption, minimise environmental impact and ensure continuous improvement in energy management processes.
1.2. To ensure that the necessary actions are taken for the implementation of legislation, national / international standards and systems related to energy management and compliance with the Company's sustainability strategies.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Employee Refers to company managers and employees.
Energy efficiency: The ratio of energy used for a given job or service to the desired output.
Energy conservation: A practice that aims to conserve resources and reduce costs by reducing energy use.
Energy performance: The performance of a system or device on energy efficiency and functionality.
Energy consumption: The total amount of energy used by a system or device in a given period of time.
Energy intensity: Refers to the amount of energy required to produce a product or service, usually measured in terms of energy consumption per unit.
3 SCOPE
This is politics;
Members of the Board of Directors of the Company,
Company managers and employees,
Companies and their employees from which goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 DUTIES AND RESPONSIBILITIES
4.1. Board of Directors
4.1.1. The Board of Directors is responsible for overseeing the formulation, implementation and updating of the Policy.
4.2. Environment Department
4.2.1 The Environment Department is responsible for the formulation, implementation and updating of the Policy on behalf of the Board of Directors.
4.3 Employees
.4.3.1 Company employees are obliged to act in accordance with the principles contained in the policy and in no case can they be forced to act contrary to the Policy. Employees are obliged to report all behaviours and practices contrary to this policy to their managers.
4.3.2 Managers are responsible for the correct application of the principles in the policy by the employees, subcontractors and their employees and business partners for whom they are responsible.
5 APPLICATION PRINCIPLES
5.1 The Company uses the rapidly decreasing energy resources in the world with the principle of minimum energy maximum efficiency within the framework of legal regulations.
5.2 The Company carries out design activities to improve energy performance and efficiency.
5.3 The company continuously improves its energy performance by setting concrete targets to increase energy efficiency in its activities and monitoring these targets at regular intervals.
5.4 The Company makes continuous efforts to reduce energy consumption and improve energy efficiency, and uses new technologies to reduce energy intensity, promotes energy-efficient practices, and regularly reviews processes and equipment related to energy consumption.
5.5 The Company organises regular training programmes to raise awareness and educate all employees and stakeholders on energy management, and encourages all stakeholders to contribute to energy management by emphasising the importance of energy efficiency and sustainable energy use.
6 CONTACT
6.1. The Energy Policy has been announced to the Company's employees and is constantly and easily accessible through the corporate website.
6.2. The Company organises trainings to raise awareness of employees on environmental issues.
7 ENFORCEMENT
This Quality Policy was put into effect with the Board of Directors Decision dated 1.10.2024.
This Energy Policy will remain valid and in force until a new announcement is made.
8 SUPPORTING DOCUMENTS
EN-PL-017 SUSTAINABILITY POLICY
EN-PL-004 ENVIRONMENTAL POLICY
Information Security Management System Policy
1 PURPOSE
The purpose of the Information Security Policy (hereinafter referred to as the “Policy”) is to determine the information management principles and rules, reporting and responsibilities of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“).
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Employee Refers to company managers and employees.
Information Security: It includes processes related to the protection of information against unauthorised access, change or destruction.
Information Access: The authorisation of specific users, systems or processes to access information.
Information Confidentiality: Protecting sensitive or private information from unauthorised persons and keeping it confidential.
Information Integrity: Information is reliable in terms of accuracy, completeness and unchanged.
Information Security Management System: The system established by the company to manage and improve information security processes.
3 SCOPE
This is politics;
Members of the Board of Directors and Employees of the Company,
covers.
4 DUTIES AND RESPONSIBILITIES
4.1.1 The IT Department is responsible for the creation, implementation and updating of the policy.
4.1.2 The Board of Directors is responsible for the supervision of the effective operation of the IT Department in accordance with the principles and guidelines set forth in the Policy.
4.2 Employees
.4.2.1 Company employees are obliged to act in accordance with the principles contained in the policy and in no case can they be forced to act contrary to the Policy. Employees are obliged to report all behaviours and practices contrary to this policy to their managers.
4.2.2 Managers are responsible for the correct application of the principles in the policy by the employees, subcontractors and their employees and business partners for whom they are responsible.
5 APPLICATION PRINCIPLES
1. The company ensures Information Security Management System ISO 27001 compliances in information management.
2. The Company ensures confidentiality by providing only authorised access to information.
3. The Company protects the information against unauthorised changes and ensures integrity by recording the changes made.
4. The Company ensures accessibility by making information available to authorised users when needed.
5. The company fulfils all legal requirements and ensures that they are implemented by each unit.
6. The company raises awareness by providing continuous training on Information Security for all employees.
7. Within the company, all Information Security gaps and suspicious situations detected are reported to the relevant persons. Continuous improvement and controls are provided by those concerned.
8. The Company attaches great importance to ensuring the safety of products and services offered to customers and stakeholders.
9. The Company aims to ensure that all business processes are integrated, harmonised and balanced with each other. With its integrated and dynamic business strategy, it protects the security, confidentiality, integrity, accessibility and continuity of information assets.
10. The Company takes measures against risks that may threaten the security, confidentiality, integrity and accessibility of products and services that provide value to customers and stakeholders and adopts systematic risk management.
11. The Company manages information security in compliance with all relevant legal regulations.
12. The Company establishes and publishes sub-procedures and internal control mechanisms in accordance with the Information Security Policy and audits the implementations.
13.The Company determines information security targets in line with this policy and organisational objectives, regularly measures compliance and thus evaluates opportunities for continuous improvement.
14. The Company, all units and employees carry out their activities in accordance with all legal regulations, company commitments and contracts in accordance with this policy and Information Security Management System standards.
15. The Company establishes the necessary mechanisms to continuously improve and develop the Corporate Information Security Management System; makes the necessary updates and improvements in the system by following innovations and technological developments.
16. The Company considers imposing disciplinary penalties and criminal sanctions within the scope of the relevant legislation within the scope of violation of corporate information security policies and procedures.
6 ENFORCEMENT
This Information Security Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Information Security Policy will remain valid and in force until a new announcement is made.
7 SUPPORTING DOCUMENTS
EN-PR-018 BGYS OPERATING PROCEDURE
EN-PL-009 HUMAN RESOURCES POLICY
EN-PL-011 QUALITY POLICY
ISO 27001:2022 INFORMATION SECURITY MANAGEMENT SYSTEM
Code of Ethics Policy
1 PURPOSE
The Code of Ethics Policy (hereinafter referred to as the “Policy”) covers all businesses and activities of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“) and has been prepared with the aim of outlining the ethical rules and principles that all employees, business partners and suppliers are expected to comply with and the governance structure in this regard and providing guidance on implementation.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Policy Code of Ethics Policy
Employee Refers to company managers and employees.
3 SCOPE
This is politics;
Managing Director of the Company,
Company Employees,
Companies and their employees from which goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 PRINCIPLES AND GUIDELINES
4.1. Legal Responsibilities
4.1.1. In order to carry out its activities in a sustainable manner and to protect the environment, the Company designs its investments and power plants in accordance with the relevant legislation and regulations, and goes beyond legal requirements where it can. It acts within the framework of laws and international legal rules while carrying out all its domestic and international activities, works in cooperation with all public institutions and organisations, and provides all kinds of information, documents, documents and notifications requested from it in a timely and understandable manner.
4.1.2. It shows sensitivity in complying with the rules and requirements of all legislation related to the Company's activities, especially financial legislation and environmental legislation, and expects the same from third parties and institutions with which it cooperates. The Company is always honest in its dealings and communication with public officials and does not try to influence their decisions with gifts, aid, bribes or other unethical offers.
4.2. Responsibilities towards Customers
4.2.1. The Company's primary goal in all areas where it does business and operates is to meet customer expectations at the highest level. From this point of view, the Company constantly endeavours to develop new products that will improve their quality of life and encourage responsible consumption by anticipating the needs of its customers in the most accurate way. It constantly renews and improves itself by taking into account customer satisfaction and all kinds of feedback from customers. With its customer-oriented working approach, it works with an understanding that finds answers to all needs, demands and expectations of customers as soon as possible and focuses on eliminating the problems that will arise as soon as possible.
The Company guarantees the confidentiality of the personal data of all its customers and undertakes not to share this data with third parties without the consent of its customers, except for legal obligations or court orders. The collection, use, processing and storage of the personal data of its customers are carried out in a manner that guarantees their privacy rights and complies with the relevant legal regulations.
It is one of the basic principles of the company to provide its services on time and under the conditions promised. The Company addresses both its internal and end customers with respect and courtesy and adopts a transparent and honest approach. The Company pays attention to ensure that commercial agreements with its customers are organised in such a way as to avoid misunderstandings and acts with the principle of transparency in the pre-agreement processes.
4.3. Responsibilities towards Employees
The basic building blocks of the company are its employees. For this reason, it values its employees as its most important resource and acts with an understanding that will enable them to work in good conditions, in harmony, satisfied with their work and adopting the work.
The Company evaluates candidates according to objective criteria in recruitment processes. It makes its selections based on meeting the requirements of the position, talent and ability, and offers equal opportunities to all candidates. The Company guarantees that no employee is discriminated against on the basis of personal characteristics such as language, religion, ethnic origin and gender in all processes from the recruitment stage to career and remuneration practices, and does not allow otherwise.
It takes all necessary measures to create a safe working environment in its businesses and fields of activity. Complies with the requirements of the relevant legislation and takes all measures deemed necessary in addition to the legislation. Organises compulsory and voluntary trainings for its employees on occupational health and safety issues, and ensures continuous access to training materials.
Ensures that its employees fully and completely exercise their rights arising from laws and contracts. Respects freedom of representation and collective bargaining rights.
Supports the personal and professional development of its employees and provides them with the training they need. It values its employees as individuals, keeps their personal information confidential and uses this information only within the framework required by law.
4.4. Responsibilities towards Competitors
The Company believes in the necessity of a free market in business life and acts to protect the competitive structure in all its activities such as price determination, trading conditions, discounts and customer selection. It competes in compliance with the laws within ethical rules and avoids unfair competition. It does not try to learn confidential information about its competitors, does not rely on information that reaches it outside of legal means and does not use such information. It does not make any statements and actions that humiliate its competitors and damage their reputation. Respects their copyrights. It expects its competitors to behave in the same way.
In all kinds of marketing activities such as products, services and promotions, especially in advertising ethics, the Company acts honestly and realistically in accordance with legal regulations and general morality, and avoids any action that may damage the reputation of the Company's name, and avoids including expressions or phrases that disparage its competitors or its competitors' products in its announcements, advertisements and advertisements.
4.5. Responsibilities towards the Society and Humanity
The Company aims to create sustainable value for its stakeholders within the scope of its Sustainability Strategy and acts to contribute to the goals of the Sustainable Development Goals. It contributes to the society in which it operates with its activities and sustainable development strategy. It works by respecting human rights and the values of different societies, and takes care not to contradict the generally accepted lifestyle, world view and traditions of the society in its activities both in Turkey and in other countries.
In the societies where it does business, it works to improve the education, culture, economy and social well-being of these societies, avoids all kinds of attitudes and behaviours contrary to human rights such as illegal employment and abuse of child labour, abusive words and treatment against workers, involuntary labour and similar attitudes and behaviours, expects all suppliers and business partners to act in accordance with these issues, terminates commercial relations with persons and institutions that it learns that they do not carry the necessary sensitivity in this regard.
It does not include elements contrary to the fundamental values of society such as sexual abuse and violence in its advertisements and avoids any symbol, expression or implication that may lead the society to negative habits. It does not make adverts derogatory to any political view, religion, language or ethnic group.
4.6. Responsibilities towards the Environment
The Company conducts its activities with the principles of respect for and protection of the environment, complies with relevant environmental legislation and standards 100% and works to minimise its environmental impact in line with its sustainability strategy.
Knowing that fulfilling responsibilities towards the environment also means fulfilling responsibilities towards employees, society and humanity, the Company acts with environmental awareness during all its services and activities and operates its facilities at standards that will not cause environmental pollution.
Develops and implements ways and methods to minimise the long-term negative environmental impacts of its activities within the scope of its sustainable growth strategy. Minimises the consumption of natural resources during all manufacturing processes, including the construction infrastructure, heating, cooling, electricity and water installations of all its facilities. It invests in energy efficiency to reduce its carbon footprint.
4.7. Information Security and Social Media
The Company undertakes to comply with all legal regulations, legislation and standards specified in ISO 27001 regarding information security and personal data. It is defined as all data, text, picture, sound and similar contents in physical or digital media that are produced, used, transmitted, archived or legally transferred to the company in business processes. Strategic information, organisational information, commercial, technical, financial data, customer dealer information, policies, procedures, regulations, product, service information, employee personal information and all other information including but not limited to these are considered within this scope.
Within the company, all kinds of information related to the business and not open to the public are considered confidential information, and this information is not shared with third parties outside the company, except for the requirements of the current task. Although transparency is the main principle within the company, care is taken to share information to the extent required by the current task.
All information developed by company employees, acquired by the company or revealed within the requirements of the business belongs to the company and is considered a trade secret. The company's products, services, financial information, technical information, business development information, information about customers, suppliers, employees and all kinds of similar data that are not shared with the public in written and printed form, electronic media or computer programmes belong to the company and are considered confidential information.
All employees are responsible for the healthy operation of information security systems established to protect confidential information within the Company within the scope of their individual duties. Company employees show due diligence to ensure that any information and/or document they use and access while performing their duties is not lost and that the accuracy or integrity of such information and/or document is not impaired.
Company employees are aware that all information (financial information, customer information, personal information of personnel, etc.) and/or documents they access due to their duties are confidential and they do not share them with third parties (persons outside the Company). Personnel act in accordance with the principles of loyalty, confidentiality and non-competition.
Within the framework of encouraging communication opportunities and the necessity of business life, social media is widely used in the Company. Social media or internet services are primarily available for business use and to a limited extent for personal use. Employees are aware that all kinds of information accessed and sent electronically are monitored and controlled by the company. It is the responsibility of the employees to protect the passwords used for internet access and e-mail services.
In addition to the above-mentioned general principles on information security and the use of social media tools, some examples can be given as follows.
Employees for information security,
They should attach importance to the confidentiality of confidential and/or trade secret information and adhere to the principles of loyalty and confidentiality.
They report information security violations, security gaps and all kinds of suspicious situations within the organisation to the relevant units and persons.
Protect the confidential and private information of employees, customers, suppliers, business partners and other persons and organisations they work with and do not use this information for purposes other than business purposes.
They do not share the information learnt and the documents obtained as a result of work with unauthorised persons and authorities inside or outside the Company, and they do not use them for personal purposes in any way.
Even after leaving the Company, they do not use the information and documents they have against the Company or in favour of competitors.
They attach importance to the protection of intellectual property such as patents, trade secrets, copyrights, names and trademarks.
They do not forget that it is forbidden to gain profit through the stock exchange or any other means by leaking any confidential information and/or documents within the scope of “Insider Trading”.
When some information needs to be shared with third parties due to business requirements, they ensure that this information is shared in a way that will not harm the company (Confidentiality agreement, etc.) by informing the information security/relevant unit and obtaining approval from the senior manager.
They do not forget that the e-mail account provided by the company is allocated for company business and can be supervised.
They do not use the technological communication tools provided to employees in order to exchange information within the business relationship for their personal purposes.
Avoid any behaviour that may threaten the physical/environmental security of PC, Laptop, Server and similar information processing and production devices.
Ensure that information and documents requested by Regulatory Authorities and Independent Auditors are shared accurately, clearly and timely in accordance with company practices.
They apply to the information security unit in case of unauthorised/unintentional access, exposure or sharing of confidential information for any reason.
Individual visitors come with reasonable frequency and in such cases, interviews are held in the canteen, cafeteria or interview room after the approval of the unit managers.
They do not take any electronic and/or written documents (cd, portable memory, etc.) containing information and data outside the company for non-business purposes. (If necessary, the approval of the manager is obtained.)
They know that the Information Technologies Department is authorised by the Information Technologies Department to install software on the entire system and they do not install or use programs that will enable the sharing or downloading of files such as music, pictures, films, etc. on the internet.
“They do not send so-called ”chain letter" e-mails.
Necessary care and attention should be taken in the use, sharing, storage, protection of the accuracy and integrity of all kinds of information and documents. The published “Information Security Policy” document must be complied with, and since the issues to be complied with are explained in detail in this document, the relevant document must be obtained and read.
4.8. Relations with Suppliers and Customers
Company employees do not benefit personally from commercial transactions with suppliers and customers, do not use corporate information and positions for their own benefit, do not engage in commercial competition with the company, and do not have close relations with persons or organisations that will benefit from the information they have due to their job. In this sense, employees shall not be the owner or profit partner of a supplier or any competitor with whom the company has a direct business relationship.
In business relations with organisations owned or profit-owned by relatives of employees, it is expected that business conditions parallel to similar suppliers/customers are provided, that these conditions are demonstrated by periodic internal audit reports, and that the business relationship in question is completely outside the employee's individual field of duty. However, even if all these conditions are met, the General Manager's explicit consent of the relevant company is required.
Employees should not have a financial interest relationship with suppliers/customers and competitors, such as lending and borrowing, suretyship and similar financial interests, in addition, their social relations with suppliers/customers should not be at an intensity that may damage the professional business relationship and their personal purchases from suppliers should not be of a nature that may carry advantages beyond the usual commercial conditions.
In principle, the Company does not accept gifts from business partners. However, gifts to be received from business partners (or to be given to business partners) may be accepted if they comply with commercial practices and the Donation and Aid Policy, remain within the framework of goodwill and do not affect the objectivity of their decisions. Any doubts that may arise in this regard can be resolved by taking into account the limits and rules determined in the Donation and Aid Policy.
The Company works to raise awareness among its suppliers on environmental, social and broader sustainability issues. When selecting suppliers to work with, the Company observes minimum environmental and social criteria, and does not work with suppliers that are found not to fulfil certain human rights criteria.
In addition to the general principles mentioned above for relations with suppliers and customers, some specific situations can be specified as follows.
Employees may not use their duties and authorities in the organisation in any way for personal or private benefit for the benefit of themselves, their families or third parties.
Employees working in the purchasing functions of the Company do not establish individual commercial relations with suppliers with whom they are in contact due to business relations.
If an employee who has left the workplace becomes a potential supplier -except for special permissions obtained from senior management-, no commercial relationship can be established between him/her and the organisation for two years. If the person has left the workplace by becoming a partner of a supplier with whom he/she previously had a business relationship, the existing commercial contracts are re-evaluated and the Ethics Committee's opinion is taken into consideration.
Employees do not make a request to any supplier company with which they have a business relationship due to their duties in the company for the recruitment of their relatives or acquaintances.
Employees may participate in activities organised by customers or customer institutions provided that they stay within acceptable limits (with the knowledge of the company's senior management).
Meals eaten during meetings where business matters are discussed and reviewed, or other expenses appropriate to the requirements of the business, may be authorised to be paid by customers or suppliers.
4.9. Use of Institutional Resources
The movable and immovable properties belonging to the company, all kinds of material benefits, human and information resources obtained with the company's means constitute the corporate resources. The interests of the organisation are taken into consideration in the use of resources on behalf of the Company. The Company provides its employees with all necessary and appropriate resources to fulfil their professional responsibilities.
Company employees agree to use the resources provided to them to fulfil their professional responsibilities responsibly and only for the organisation. In particular, the employment of human resources in line with the interests of the organisation is essential, and the assignment of employees by managers for their personal affairs is a violation of this principle.
Employees are expected to use all kinds of vehicles, fixtures, goods and facilities allocated for work without damaging them, within the framework of due diligence obligations and only for the organisation. For example,
Long personal calls on an allocated telephone,
Excessive and unwarranted expenses incurred while travelling on business,
Allocation of company staff time to the personal affairs of the manager,
Use of the company vehicle for the benefit of third parties that cannot be directly associated with the organisation,
Any behaviour that prevents the use of common areas or damages fixed assets,
can be evaluated in this context.
4.10. Responsibilities of Managers
All professionals working in managerial roles within the company must have all the necessary skills, experience, qualifications, training and expertise to perform their duties and responsibilities. In addition, all managers must act transparently, responsibly, efficiently and honestly, and perform their work with the principle of excellence in the interests of the organisation. All managers in the company are obliged to continuously improve all the mentioned characteristics and capabilities.
Managers at all levels of the Company adopt the Code of Ethics and set a pioneering and exemplary example for the adoption of the Code of Ethics among unit employees. In this context, managers,
They encourage their subordinates for sharing, questions and opinions about the Code of Ethics.
They take every issue consulted on ethics seriously and, if necessary, forward it to the Ethics Committee as soon as possible.
They create business processes in a way to minimise the risks related to ethics by taking into account the entire ethics procedure during the construction of the works under their responsibility.
They know the instructions and regulations published within the organisation and follow all kinds of changes and inform their subordinates as necessary.
Immediately inform the senior management about legal issues concerning the organisation, and do not resort to individual solutions.
They are willing to take initiative in their duties and do not consciously avoid using their authority and responsibilities.
All managers working within the Company operate in compliance with legal regulations, legislation and the Company's policies and procedures. In this context;
Environmental Policy and behaviours for the protection of the environment,
Diversity and inclusion in all its decisions, anti-discrimination, and the Human Rights Policy in this context,
Behaviour towards occupational health and safety, taking necessary measures to prevent occupational accidents and diseases,
Human Resources Policy and related procedures and requirements in the recruitment, evaluation and training processes of all employees,
adopt, implement and pioneer in raising awareness.
4.11 General Responsibilities of Employees
Each individual within the Company is an asset and his/her participation in business life with his/her unique lifestyle and world view is worthy of respect. Within the scope of the Code of Ethics, the ethical principles that the Company expects and obliges all employees to comply with are specified in terms of main topics. In this section, the attitudes and behaviours that each Company employee should show in business life and especially in the office environment are as follows in general terms.
Staff,
They do not harass and disturb their colleagues physically, psychologically and socially, and do not engage in violent attitudes and behaviours.
They do not use drugs and/or stimulants and/or alcohol in the offices and never come to the workplace in this way.
They shall only lend to legally authorised institutions and organisations, and shall not enter into debt and surety relations with each other in a manner that may undermine the image of the institution.
They do not commit theft, abuse of security, forgery, fraud, slander, bribery, embezzlement crimes (disgraceful crimes) inside and outside the company, and fulfil their duties and responsibilities to the state as individuals who respect the social law and laws.
When their business relations with the Company are terminated, they deliver the information and documents within the scope of their duties to their organisations in full.
They work with the effort and goodwill to fulfil the duties and responsibilities specified in their job descriptions with a minimum level of error.
They know and follow the working hours determined and announced for them, they report an excuse when they do not come to work during working hours or when they come late, they do not change their working hours without the knowledge of the manager or the Human Resources Department.
They attend the trainings planned for them and all organised meetings.
In the event that they have information about violations of practices within the company, they report this to their senior manager and/or the relevant unit.
Full-time, contracted and part-time employees, including paid/unpaid leave periods, do not work in a similar line of business in competitor companies. Since it is inappropriate to work in side jobs or in consultancy and similar positions that require remuneration to be paid to them, the employee informs his/her supervisor in this case and consents to the evaluations to be made in terms of competition, loyalty and performance due to his/her work.
They know that false, misleading and exaggerated information in communication will prevent the transfer of the correct message and therefore they pay attention to establish healthy communication.
4.12. Evaluation of Incompatibilities
The Company expects employees to take into account the Company's values and determine their behaviour in line with these values when they are in a dilemma about how to behave in order to comply with high standards.
As can be seen from the examples below, unethical situations and behaviours can be encountered in many different dimensions.
Managers giving unethical instructions and directions to their subordinates,
The employee's own behaviour contrary to ethical rules and corporate values,
The employee sees his/her colleague in a behaviour contrary to ethical rules or corporate values,
In ongoing relationships with business partners (customers, suppliers, etc.), the owners, managers or personnel of these companies make unethical offers or demands to their employees.
Employees making unethical offers or requests to business partners (customers, suppliers, etc.).
If employees are aware of or suspect a violation of ethical rules or corporate values, they should share this information with their senior managers and, if necessary, with the members of the Ethics Committee within the framework of the following criteria. In case the employee detects behaviours that he/she may consider unethical or potentially incompatible with the Company principles and professional business ethics, he/she should ask himself/herself the following questions and act according to the answers given:
Is the behaviour contrary to Company principles and business ethics?
Is the behaviour contrary to professional standards and the rules set out in the Code of Ethics?
Does the behaviour conflict with the interests of the organisation?
Would the behaviour have negative consequences for the company if the public, customers and other stakeholders heard about it?
Is the behaviour clearly contrary to the law and corporate regulations?
If a third party outside the company objectively evaluated the situation witnessed, would they perceive this situation as unethical?
The employee should analyse the situation and if he/she answers “yes” to one or more of the above questions, he/she should report this situation to the relevant authorities.
5 DUTIES AND RESPONSIBILITIES
5.1. Boyçelik Ethics Committee consists of a chairman, three members, an independent member (an expert consulted on the relevant subject in case of need) and a secretariat and after the approval of the General Manager, it starts its activities by being announced to all employees by the Human Resources Department. Duties and Responsibilities of the Ethics Committee:
Investigating complaints and denunciations of violations of the Code of Ethics within the Company,
To decide on or have investigated violations of the Code of Ethics,
To make opinions and suggestions for the implementation of the Code of Ethics,
Responding to applications made for consultancy purposes within the scope of the Company Code of Ethics,
To ensure that the Code of Ethics is in compliance with legal regulations,
To inform employees about the Code of Ethics, to be in constant communication with employees in order to ensure the comprehensibility of policies and rules,
Ensuring that all new recruits and employees read the Code of Ethics and are informed about it.
5.2. All employees may verbally report their questions about the code of conduct and suspected violations, as well as use the following communication channels of the Ethics Committee.
E-mail: etik@boycelik.com.tr
Address: O.S.B. 37th Cad. No:4, 38070 Melikgazi, Kayseri, Turkey
5.3. In addition to its function of evaluating violation notifications, this committee is a body where all employees can consult with the situations they suspect and the dilemmas they experience regarding ethical issues. It is also open to all kinds of suggestions from employees in order to improve ethical awareness in the company and to take protective/preventive measures to prevent ethical violations.
5.4. In the notifications made to the Ethics Committee, it is under the assurance of the Ethics Committee of the Company that the notification to be made will not have any negative impact on the employee, provided that the employee making the notification does not make notifications out of good faith, and also that any notification to be made will be kept absolutely confidential.
5.5. Complaints and notifications received by the Ethics Committee are handled and investigated within the framework of confidentiality principles and each stage of the investigation is definitely recorded. The Ethics Committee is authorised to receive relevant information, documents and papers from any unit it deems necessary in relation to the matter it investigates. The Board takes the necessary measures to conclude the investigations related to violations quickly, and if deemed necessary for the fair conduct of the investigation, it may receive support from experts and specialists, taking into account the principles of confidentiality. Reported or detected rule violations may be resolved by the Ethics Committee Chairman, taking into account their nature and effects, by the company's ethics committee, or they may be referred to the company's disciplinary board and resolved without the participation of the Ethics Committee.
5.6. The Ethics Committee carries out its activities with the assumption that each employee acts in accordance with the ethical rules unless the contrary is concretely demonstrated. An employee against whom a complaint or notification is made on the grounds of unethical behaviour is given the opportunity to express himself/herself within the scope of the complaint/notification. In addition, during the investigation process, it is accepted that the employee has not committed any violation until the allegations about the employee are concretely verified.
5.7. The Ethics Committee convenes upon the invitation of any of the Board Members when a notice is received or an opinion is requested. The Board may invite persons it deems appropriate to the meetings to obtain information on issues deemed necessary. The Chairman of the Ethics Committee is responsible for the implementation of the Ethics Committee working principles.
6 REVIEW
This Policy is reviewed by the Ethics Committee on a regular basis once a year, based on the controls related to process or technical infrastructure changes. This revised and updated policy is approved by the General Manager.
7 ENFORCEMENT
This Policy was put into effect with the General Manager Decision dated 01.10.2024. This Policy will remain valid and in force until a new announcement is made.
8 SUPPORTING DOCUMENTS
EN-PL-002 DONATION AND AID POLICY
EN-PL-004 ENVIRONMENTAL POLICY
EN-PL-008 HUMAN RIGHTS POLICY
EN-PL-009 HUMAN RESOURCES POLICY
EN-PL-017 SUSTAINABILITY POLICY
Communication Policy
BOYÇELİK
COMMUNICATION POLICY
Main Process Corporate Communications
Sub Process: Corporate Communication
Policy Communication Policy
Policy No:
First Implementation Date:
Approved by:
Amendment No:
Last Modified Date:
Approved by:
ARTICLE 1. PURPOSE
The purpose of the Communication Policy (hereinafter referred to as the “Policy”) is to determine the standards and expectations required to create a strong communication structure based on the principle of honesty, transparency and professionalism in all internal and external communication processes of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“).
ARTICLE 2. DEFINITIONS
2.1. In this section, specific terms and concepts used in the policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Policy Communication Policy
Employee Refers to company managers and employees.
Internal Stakeholders: Company Senior Management and Employees.
External Stakeholders: Persons, groups or institutions/organisations outside the Company that are affected or influenced by the Company. These include the Company's customers, the public, suppliers, business partners, investors, local communities, public institutions and regulatory bodies, academic institutions, financial institutions, non-governmental organisations, sectoral organisations and professional organisations, and media organisations.
ARTICLE 3. SCOPE
3.1. Policy,
All employees of the company,
Companies from which goods and services are purchased, all business partners and employees,
External service providers; persons and organisations working on behalf of the Company, including consultants, lawyers, advisors and external auditors, and the entire value chain, including customers with whom the Company has commercial relations
covers.
ARTICLE 4. PRINCIPLES AND GUIDELINES
4.1. Communication Rules
4.1.1. Transparency
4.1.1.1.1. The Company adopts the principle of transparency and accuracy in communication. It encourages the sharing of true, accurate and up-to-date information in internal and external communication. It is absolutely unacceptable to communicate misleading or manipulative information.
4.1.2. Honesty and Ethical Principles
4.1.2.1. The Company strictly complies with universally recognised ethical principles and the Code of Ethics in all communication processes.
4.1.3. Privacy and Data Security
4.1.3.1. The Company is obliged to protect the confidentiality of customer information, trade secrets, employee data and other sensitive information. In communication processes, confidential information is shared only between authorised persons and full compliance with the relevant laws is ensured.
4.1.4. Communication and Feedback
4.1.4.1. Communication should be reciprocal and interactive, not one-way. The company establishes an open communication channel with employees, customers and other stakeholders and encourages the processes of receiving and giving feedback. It makes continuous improvements by taking these feedbacks into account.
4.1.5 Cultural Sensitivity and Diversity
4.1.5.1. The company encourages effective communication between different cultures and language groups. It respects cultural diversity and creates an environment where everyone can express themselves in communication processes. It does not discriminate on the basis of race, gender, religion or other personal characteristics.
4.2. Communication Methods
4.2.1. The methods to be used when communicating with stakeholders are included in the Stakeholder Engagement Policy [TM1].
4.2.1.1. The preferred channels for internal communication are internal communication platforms such as e-mail, instant messaging, meetings, etc.
4.2.1.2. In external communication, communication with customers is usually carried out by e-mail, telephone or face-to-face meetings. Social media platforms are also carefully used by persons representing the Company.
4.2.2. Any suspicion or violation of the Code of Ethics Booklet, Anti-Bribery and Anti-Corruption Policy, Donation and Aid Policy, Human Rights Policy and Competition Policy[TM2] can be contacted via the Ethics Line.
E-mail: etik@hes.com.tr
Address: Erciyes Mahallesi, Hes Caddesi No:22 38210 Hacılar/KAYSERİ
4.3. Communication in Emergency Situations
4.3.1. Communication methods used in emergencies are included in the Emergency Plan [TM3].
4.4. Record Keeping
4.4.1. All communications are recorded in writing whenever possible. These records should include the following information.
Minutes of the meeting,
Original copies of communications in any format, such as correspondence, notes, electronic mail, posters, etc.
4.4.2. The records of the communications related to the Management Systems should be organised and stored in such a way that they can be easily accessed and reviewed. For this purpose, the “Communication” folder created on the public network is used. [TM4]
ARTICLE 5. SCOPE AND RESPONSIBILITIES
5.1. Board of Directors
5.1.1. The Board of Directors is responsible for overseeing the formulation, implementation and updating of the Policy.
5.2. Sustainability Committee
5.2.1. Responsible for managing the processes related to Stakeholder Engagement together with the XX Department.
5.3. Department XX[TM5]
5.3.1. XX Department is responsible on behalf of the Board of Directors for the creation, implementation and updating of the Policy.
5.3.2. XX Department is responsible for establishing correct and effective communication with internal and external stakeholders and establishing the necessary communication mechanisms.
5.3.3. Responsible for managing the processes related to Stakeholder Engagement together with the Sustainability Committee.
5.4. Department Managers
5.4.1. Department Managers are responsible for the implementation of this procedure in their own work area and for ensuring that the subcontractors they work with work in accordance with this procedure.
5.4.2. Department Managers are responsible for the effective and timely provision of the necessary organisational and technical resources for the realisation of communication.
5.4.3 Department Managers are responsible for ensuring that employees and subcontractors under their responsibility are trained in the scope of this procedure.
5.4.4 Department Managers are responsible for ensuring and following up the realisation of action plans determined for communication.
5.4.5. Department Managers are responsible for ensuring that communication needs arising from risk assessments are met.
5.4.6. Department Managers are responsible for monitoring and developing the system for continuous improvement.
5.5. Employees
5.5.1. He/she is responsible for attending the meetings in which he/she is interested and requested to attend.
5.5.2. To use relevant communication methods in the process of performing his/her duties,
5.5.3. Responsible for giving feedback / sharing their views on the effectiveness of the communication and potential risks they see, firstly to their supervisor or manager and to Department XX [TM6].
ARTICLE 6. EFFECTIVE
6.1. This procedure has been put into effect by the Decision of the Board of Directors dated XX [TM7]. This procedure will remain valid and in force until a new announcement is made.
ARTICLE 7. REVIEW
7.1. This procedure is reviewed by the XX Department on a regular basis once a year, based on controls related to process or technical infrastructure changes. This revised and updated procedure is approved by the Board of Directors.
ARTICLE 8. RELEVANT POLICIES AND PROCEDURES
Human Resources Policy
Stakeholder Engagement Policy
Code of Ethics Booklet
Anti-Bribery and Anti-Corruption Policy
Donation and Aid Policy
Human Rights Policy
Competition Policy
Emergency Plan
[TM1]Hyperlink: Stakeholder Engagement Policy
[TM2]Hyperlink: Related policies should be hyperlinked when the policy is published.
[TM3]Here you can refer to the emergency plan, if any.
[TM4]We recommend setting up such a folder to act as an archive.
[TM5]Corporate Communication Departments are responsible for managing communication channels in Communication Policies, but since there is no such unit in the Form Sünger organisation chart, it will be revised here with the responsible unit you will determine.
[TM6] Corporate Communication Departments are responsible for managing communication channels in Communication Policies, but since there is no such unit in the Form Sünger organisation chart, it will be revised here with the responsible unit you will determine.
[TM7]To be edited with the date of publication.
Human Rights Policy
1 PURPOSE
1.1. The Human Rights Policy (hereinafter referred to as the “Policy”) aims to define the human rights rules and principles that Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“) adopts and applies while continuing its activities and to create a guide for its employees, business partners, suppliers and the entire value chain in this regard.
1.2. The policy is based on the Universal Declaration of Human Rights, the United Nations (UN) Global Compact (UNGC), the UN Convention on the Rights of the Child, the core International Labour Organization (ILO) Conventions, the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and local regulations.
2 SCOPE
Politics,
All managers and employees of the company,
Companies from which goods and services are purchased, all business partners and employees,
External service providers; persons and organisations working on behalf of the Company, including consultants, lawyers, advisors and external auditors, and the entire value chain, including customers with whom the Company has commercial relations
covers.
3 DUTIES AND RESPONSIBILITIES
3.1. Board of Directors
3.1.1. The Board of Directors is responsible for the creation, implementation and updating of the Policy. It is also responsible for the supervision of the effective operation of the Ethics Committee and the Internal Audit Department, which are the notification, examination and sanction mechanisms in case of violations and suspicious situations contrary to the principles and principles set forth in the Policy.
3.2. Ethics Committee
3.2.1. The Ethics Committee is responsible for establishing the necessary communication channels for reporting violations and suspicious situations that are contrary to the principles and principles set forth in the Policy and takes measures to ensure the confidentiality and security of the persons reporting.
3.3.Internal Audit Department
3.3.1. In the event that violations and suspicious situations contrary to the principles and principles set forth in the Policy are detected, the Internal Audit Department, in accordance with the provisions of the relevant legislation, makes objective evaluations on situations that may result in Disciplinary Action. When necessary, the Internal Audit Department takes preventive and corrective measures or makes recommendations to business units and the Human Resources Department in this regard.
4 APPLICATION
4.1. The Company complies with universal standards, social values, local regulations on human rights and labour rights in all its activities.
4.2. Respect for Human Rights
4.2.1. The Company acts in accordance with universal human rights in its relations with its employees, business partners, customers, competitors and the communities in which it operates and expects to be treated with the same understanding.
4.3. Child Labour and Forced Labour
4.3.1. The Company does not tolerate attitudes and practices contrary to human rights and legal regulations such as child labour, illegal and/or forced labour, ill-treatment of employees, unregistered employment.
4.4. Violence and Ill-Treatment
4.4.1. The Company is committed to providing all its employees with a safe and respectful environment where human dignity is not harmed. Our employees are also obliged not to use physical and psychological violence and ill-treatment against anyone, regardless of the reason, and not to condone such behaviour by others. Even if they do not take action, threats of violence and ill-treatment or attempts to instil fear for intimidation purposes are considered within the same scope. No form of physical, verbal, sexual or psychological harassment, abuse or intimidation is tolerated.
4.5. Diversity, Equality and Inclusion
4.5.1. The Company is committed to providing its employees with a working environment where they feel fully included, regardless of their differences, and where they will observe each other's rights and dignity in all their behaviours. Decisions on recruitment, placement, career development, training, remuneration and promotion are based solely on the employee's qualifications, performance, skills and experience.
4.5.2. The Company pays attention to the principles of diversity, equality and inclusiveness in its internal and external communication; elements contrary to the fundamental values of society are not included.
4.5.3. The Company supports the rights and freedoms of individuals in every field of activity. Under no circumstances is there any discrimination based on ethnic origin, gender, colour, race, nationality, economic status, religion or other beliefs. This applies to all relations with customers, employees and suppliers.
4.6. Discrimination
4.6.1. The Company does not discriminate on the basis of age, gender, race, colour, language, religion, philosophical and political opinion, ethnic origin, economic status, sexual orientation, health status, disability, appearance, clothing and lifestyle; and does not tolerate discriminatory behaviour, action or retaliation of any kind.
4.7. Right to Collective Bargaining and Freedom of Association
4.7.1. The right of employees to freedom of association and collective bargaining in accordance with the legislation shall be respected and employees exercising these rights shall not be subjected to any form of pressure or discrimination.
4.8. Occupational Health and Safety
4.8.1. Occupational health and safety is one of the Company's main priorities. The Company takes measures to minimise health and safety risks in its plants and fields of activity and carries out remedial, corrective and preventive activities for continuous improvement. It complies with the relevant legal regulations and meets the requirements. All employees are expected to follow the policies and procedures regarding occupational health and safety.
4.9. Freedom of Expression
4.9.1. The Company undertakes to prevent any situation that may hinder employees from exercising their right to freedom of expression in the work environment and provides the necessary environment for employees to express themselves freely.
4.10. Working Hours, Wages and Personal Rights
4.10.1 The Company establishes wages and benefits competitively in accordance with industry dynamics, the local labour market and the terms of applicable collective bargaining agreements. It conducts its operations in compliance with applicable laws on wages, working hours, overtime and fringe benefits. It carries out activities to increase the productivity of employees during working hours, aims to prevent overtime work, and supports the protection of work and private life balance.
4.10.1 The Company encourages the creation of a productive and motivating working environment that continuously supports development in the workplace and encourages personal development opportunities.
5 COMPLAINT MECHANISM
5.1. Violations and suspicious situations that are contrary to the principles and principles in the Company Policy are reported to the Ethics Committee via the Ethics Line. Provided that the person/persons making the notification do not make notifications out of good faith, necessary measures are taken to ensure that no pressure or retaliation is made against the person making the notification, and the violation notifications are investigated within the framework of confidentiality principles. If a situation contrary to the principles and principles in the Policy is detected as a result of the investigation, sanctions may be imposed on the responsible person(s) by the Internal Audit Department by observing the principle of equality.
Ethical Line
E-mail: etik@boycelik.com.tr
Address: O.S.B. 37th Cad. No:4, 38070 Melikgazi, Kayseri, Turkey
Details on the Ethics Committee and Investigation are included in EN-PL-006 ETHICAL RULES POLICY.
6 REPORTING AND TRANSPARENCY
The Company's human rights performance is declared annually in the Company Sustainability Report. Through this medium, commitments, activities and performance regarding human rights are announced to the public and all stakeholders.
7 RUNNABILITY
This Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Policy will remain valid and in force until a new announcement is made.
8 SUPPORTING DOCUMENTS
EN-PL-006 CODE OF ETHICS POLICY
EN-PL-017 SUSTAINABILITY POLICY
EN-PL-009 HUMAN RESOURCES POLICY
EN-PL-010 HSG POLICY
Human Resources Policy
1 PURPOSE
The provisions of this procedure regulate the principles of “General Human Resources Policy” to be applied to white and blue collar personnel working at Boyçelik workplaces and the rights, obligations and working conditions of the personnel.
2 SCOPE
The provisions of this procedure apply to personnel at all levels working in the company.
3 DUTIES AND RESPONSIBILITIES
4 DEFINITIONS
In this Procedure;
Holding: Erciyes Anadolu Holding A.Ş,
Company: Boyçelik legal entity,
Board of Directors: “Boyçelik Board of Directors” which is the highest decision-making authority of the Company,
General Manager The Senior Manager authorised to manage and administer the entire Company,
General Directorate General Manager and Deputy General Managers,
Administrator: Service Groups and Cadres ,
Personnel Blue-collar and white-collar employees appointed and working in the Company in accordance with the provisions of this regulation,
Workplace Indicates all workplaces related to Boyçelik activities.
5 PROCESS
5.1 HUMAN RESOURCES POLICY AND GENERAL PRINCIPLES
5.1.1 Human Resources Policy
The human resources policy is to determine the principles and methods to be applied in the selection, placement, remuneration, training, determination of the terms and conditions of employment and termination of employment of the personnel in order to maximise the efficiency of all works in the company by using human resources. Human Resources policy is determined and executed according to the following principles.
5.1.2Purpose
As Boyçelik Metal Sanayi ve Ticaret A.Ş. (“Boyçelik”), our aim is to increase the happiness of our employees, to strengthen their loyalty to our company and to create a work environment where everyone wants to participate. We develop and implement a fair Human Resources Policy that increases the participation of our employees in achieving our goals, unveils their potential, creates an environment that is measurable, transparent, where everyone's opinions are listened to and personal development is given importance.
Our Human Resources policies aim to create competence and skill groups that will support sustainability and fulfil the expectations of our stakeholders by maintaining our strong position in the steel industry and increasing our capacity.
Our human resources management approach aims to create the best and most productive employees and teams that are committed to ethical values, sensitive to the environment, aiming to create value, within the framework of our company's values and culture.
5.1.3 SCOPE
This policy is developed by the Human Resources (HR) department under the knowledge and supervision of the Board of Directors and updated when necessary.
The Board of Directors, company management, HR department, department and facility managers and all personnel are responsible for the implementation of this policy and related procedures.
5.1.4Basic Principles of Human Resources Policy
Our HR management approach is developed to support our sustainability policy, strategy and goals.
In order to ensure that the duties in the Company are performed in the best way possible, precise and clear descriptions of each duty are made. The qualifications required for the personnel who will carry out these duties are determined.
The limits of the authorisations and responsibilities to be assumed by the personnel at all duty levels while performing their duties are clearly stated.
The personnel are benefited from the monetary and non-monetary opportunities of the group according to fair and objective criteria and according to the value of their work for the company; to the extent of their education, knowledge, experience and skills.
Employees are evaluated according to defined performance criteria. Successful personnel are encouraged, trained and rewarded with monetary or non-monetary methods when necessary for their development and promotion to higher levels.
We create mechanisms through which our employees can convey their opinions, complaints and suggestions at any time they wish, comfortably and without being under pressure.
We support the career and competence development of our employees. We create career paths and provide mobility opportunities. We offer training opportunities where they can increase their competences and technical knowledge in different fields.
Our remuneration and fringe benefits policy takes into consideration the quality of life of our employees. We determine the total income of our employees according to the current wage market.
In addition to the salary, we offer our employees benefits such as complementary health or private health insurance, vehicle allocation and fuel support, mobile phone and company line support, and the opportunity to benefit from the products of our brands at a discount, taking into account the size of the work they carry out, representation requirements and functional needs.
Equal opportunity is one of our fundamental human resources principles. We ensure equal opportunity in recruitment, career development, competence development, promotion, performance evaluation, wages and benefits, personal rights, and fight against discrimination.
We create a supportive and understanding workplace environment where all individuals feel welcome, respected and listened to, and where they can achieve their full potential regardless of race, colour, gender, sexual orientation, age, religion, ethnic or national origin.
We adapt internal processes and procedures to support diversity and inclusion.
In promotions and appointments within the organisation, equality of opportunity is observed and the appointments to be made in managerial positions are tried to be made among the in-house personnel as much as possible.
The objectives of the company are explained to the newly recruited personnel and their contribution to the achievement of these objectives is emphasised. In certain periods, the extent to which the personnel fulfil their duties is checked and evaluated.
Managers at all levels are asked to create a work environment in line with the company's mission, based on love and respect between them and the staff in their department. The ability to create this environment is considered one of the most important qualities required in managers.
Company managers try to minimise the labour turnover rate in order to ensure work order and continuity.
Except for students (interns) and apprentices, it is essential not to employ children (15 years old and under) and young people (16 and 17 years old). If it is overlooked and his/her employment is detected later, the employment contract is terminated by giving all rights to the relevant employee. In this case, it is ensured that the necessary activities are carried out for the development of the child worker (education activities, etc.).
Protecting the rights of our employees and working in a healthy and safe environment is our top priority. We comply with all legal regulations on employee rights, occupational health and safety and working conditions.
We ensure that all business units comply with legal and regulatory obligations, the Code of Business Conduct and Values.
By taking appropriate measures, we may cooperate with the authorities and, where necessary, take legal action against employees found guilty of inappropriate behaviour under the Policy.
We ensure that working time complies with national and sectoral regulations and existing company contracts and respect the maximum permitted overtime to take into account people's work-life balance and fatigue management.
We apply disciplinary penalties in a fair and balanced manner in accordance with national, sectoral regulations and internal rules.
5.1.5Principles of Recruitment Policy
Our HR Policy covers all processes and activities of all employees from recruitment to separation, based on the principle of equality, inclusion and diversity. Our company aims to make life easier for all its stakeholders with innovative projects that encourage the success of its employees and shape the future. Our employees work with self-confidence, aware that they are part of a big team.
During the recruitment process, candidates are evaluated by observing their potential and competences as well as their work experience using various interview techniques. While the expectations of the candidates are meticulously taken into consideration, it is preferred to proceed with candidates who are suitable for the culture and goals of our company. Care is taken to ensure that our employees benefit equally from the opportunities offered by our company in pre- and post-employment processes.
In line with our corporate culture, a comprehensive orientation training is provided for new employees to quickly adapt to the company. In addition, our Human Resources team is in regular contact with the employee during rotation and job change processes. In this process, the performance, demands, satisfaction and needs of the employee are closely monitored.
a) Company managers are authorised to nominate candidates without exceeding the positions approved by the General Directorate. The General Manager decides on the recruitment of the candidates determined by the human resources and relevant department supervisors. The General Manager, together with the Chairman of the Board of Directors, decides on the recruitment of the Assistant General Manager and Department Manager. The HR Department is authorised for implementation.
b) In the recruitment of personnel, selection is made by taking into consideration the competencies and qualifications determined for the personnel who can perform that job as a result of competency analyses, job descriptions, job profiles and reference research. When necessary, exams or special tests are utilised. In the recruitment of personnel who will be in sensitive positions such as goods movements, security, records, storage, loading/unloading, order management, preparation of goods for shipment and administrative supervisors, recruitment is carried out after reference checks.
c) The department information of the recruited personnel is announced by e-mail to all departments within the company. It provides support for the creation of the necessary mail, computer, dect phone, mobile phone, software, internet and user information by Information Technologies.
d) Filling the vacant positions with personnel trained from within the company is accepted as the main principle. Under equal conditions with outsourced employees, employees within the group are preferred. In this regard, the Holding Human Resources Department ensures coordination between companies.
e) Although it is the main principle to employ personnel in the jobs they are specialised in and like, this principle is not taken into consideration for those who need to be trained in several jobs.
f) In principle, care is taken to ensure that first-degree relatives of staff members are not recruited for the same company, or even for the same department. In the course of their work, one of the married couples is transferred to another group company in the same or similar position.
g) Personnel are expected to complete their duties within working hours. It is accepted as a general principle to resort to overtime work in incidental and compulsory cases. Overtime work cannot be considered as a kind of additional work in order to increase the main wage.
h) Care is taken to ensure that superior-subordinate relations remain within a certain respect and business boundaries. Personnel who tend to violate this principle in a continuous and systematic manner shall be dismissed from the company and shall not be employed within the company again.
i) Internal communication and information flow are given due importance as a function that ensures speed and efficiency in business. For this reason, opinions, ideas and problems from all employees are carefully monitored and evaluated by company managers.
j) Boyçelik knows that it can make a difference in its sector with its employees. Each employee of the company fulfils his/her job in line with this understanding and by considering the balance of quality, speed and price.
k) The company is obliged to provide the necessary conditions for the health and occupational safety of the personnel, to keep the tools available in full, to inform the personnel in the most appropriate way about the dangers arising from the use of every tool and equipment in the workplace and the measures that can be taken in advance in this regard.
l) Personnel are also obliged to comply with the procedures and conditions regarding occupational health and safety, to act safely, and to use the personal protective equipment provided. (See Occupational Health and Safety Booklet)
5.1.6Principles of Fee Policy
a) A “remuneration system” is applied within the Group, which takes into account the importance and weight of the work performed and accordingly the education, experience and similar qualifications of the individuals, and this procedure is published by the Holding's Executive Committee.
b) Periodic increases in wages are made once or twice a year, taking into account the cost of living (inflation), market wages, seniority and achievements in work. For blue collar personnel, increases are made every 2 or 3 years within the scope of the collective labour agreement.
c) In determining the starting salaries, the salary range of the job in question, the current salaries of the personnel and market conditions are taken into consideration. The Holding Wage Policy is taken as a basis.
d) Efforts are made to satisfy the personnel in the best possible way within the framework of the existing opportunities in terms of wage system and social rights.
5.1.7Principles of Education Policy
The training of our employees focuses on contributing to the development of both the company and individuals and the creation of a sustainable life. In this context, in addition to supporting our employees to improve their competencies, we contribute to the development of corporate culture in environmental, social and governance areas.
In accordance with our human rights policy, one of our priorities is to create fair training and support processes to ensure equality among our employees and to encourage our employees to participate in these trainings. With our training procedure, it is aimed to determine the potential and existing knowledge and skills of our employees for the continuous development of their behavioural and professional competencies and to provide the necessary development tools.
Training and development planning is carried out in line with the individual development needs identified during the performance evaluation period and corporate sustainability criteria, with the perspective of having the competencies required by the career steps determined for each position. With this approach, in addition to on-the-job trainings, in-class and online trainings are offered through external training companies when needed. In addition, our experience and expertise are transferred to the future by training our own internal trainers.
For production employees, all mandatory trainings and technical development trainings, especially occupational safety, are meticulously completed and followed up.
a) It is believed that training is necessary and useful for personnel at all levels as a factor that increases productivity in the work performed.
b) Trainings Relevant trainings are planned and implemented in accordance with the Training Procedure.
c) As a general principle, the first duty of all managers, from the lowest level manager to the highest level manager, is to train and educate the staff who will take their place.
d) For domestic and, if necessary, overseas training, priority is given to highly educated, talented and foreign-language speaking staff who are considered to be promoted to higher positions in the future.
e) Employees who wish to continue their studies in postgraduate programmes are supported.
f) The Training Plan is made at the beginning of each year.
In accordance with our targets, the trainings to be given to all our employees are as follows:
Occupational Health and Safety training
Company Compliance training
Equality, Diversity and Inclusion training
Harassment and Abuse training
Cyber Security training
Business Ethics and Anti-Corruption training
The minimum training hours targeted for our employees are given below:
By 2025, every employee will receive at least 6 hours of training per year.
5.1.8Service Groups and Positions
a) Cadre Groups
All services within the company are carried out by the personnel assigned in the following 9 main groups, and our white-collar employees, whose follow-up is carried out by the human resources department, are in the sensitive personnel group.
A) General Manager
B) Assistant General Managers
C) Managers
D) Chiefs
E) Experts
F) Assistant Experts
G) Officers
H) Foreman-Postman-Responsible
I) Other Blue Collar Workers
The number of grades into which the staff groups will be divided and the remuneration grades to be based on these grades are determined by the Holding Human Resources Department and approved by the General Manager.
b) Cadres
In the company; each department, as a result of the budget work to be carried out in line with the determined targets; determines the personnel staff and submits it to the HR Department. HR submits the arrangement to the General Directorate and with this approved staff, personnel are employed for the service groups specified above.
5.1.9 Policy on Creating and Maintaining a Fair Working Environment
Boyçelik Metal Anonim Şirketi considers the creation and maintenance of a fair working environment for employees as one of its top priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment in compliance with all relevant laws and regulations. The following code of practice sets out the basic principles for the creation and maintenance of a fair working environment at Boyçelik Metal Company.
Application Guidelines
1. Company practices comply with all applicable laws and regulations regarding employment and working life. Company employees also fulfil all legal requirements within the scope of their activities and act in accordance with legal regulations.
2. Boyçelik Metal human resources policies and practices ensure that all other practices such as recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. are fair.
3. It is unacceptable to discriminate among employees within the institution on the grounds of language, race, colour, sex, political opinion, belief, religion, sect, age, physical disability and similar reasons.
4. A positive and harmonious working environment that supports co-operation is created in the company and conflict environments are prevented and people with different beliefs, thoughts and opinions are ensured to work in harmony.
5. Employees' private life and personal spaces are respected.
Communications between individuals may not be infringed by non-parties.
Even if it is recorded in accordance with the law, it is forbidden to give/disseminate/obtain personal data to others unlawfully.
Personnel personal information arising from the nature of the business relationship in the workplaces and which may be necessary in the continuation of the business relationship is not used for purposes other than its purpose and is not shared with third parties without the consent of the persons.
The private and family life of all employees is respected.
6. In addition to all kinds of inviolability of employees, their physical, sexual and emotional inviolability is also observed.
It is against the law and ethical rules to violate the inviolability of employees in any way through physical, sexual and/or emotional harassment in the workplace or anywhere they are present due to work, and this crime is not tolerated by the Company in any way. The purpose of this practice is to ensure that employees work in a work environment where their physical, sexual and emotional immunity is protected.
Violation of a person's bodily inviolability through sexual behaviour and/or harassment of a person for sexual purposes without physical contact is defined as sexual harassment. Accordingly, any behaviour that can be considered within this definition is prohibited.
Furthermore, no tolerance is shown to those who behave in a negative manner towards those who make complaints and reports about any harassment or assist in the investigation.
7. No employee may demand privileged treatment, show privilege to anyone or be subjected to special treatment due to different gender, religion, language, race. It is unacceptable to take or give concessions by taking advantage of differences such as gender, religion, language, race. This is clearly stated in the Business Life and Corporate Ethics Handbook. In case of any discrimination, it is clearly stated where and how the employee can apply.
8. In case of violation of these conditions, the Workplace Disciplinary Procedure shall be carried out from the detection of the incident.
5.1.10 DIVERSITY, EQUALITY, EQUAL OPPORTUNITIES AND ANTI-DISCRIMINATION
Respecting differences is not only essential for the proper fulfilment of work, but also for achieving success. In this context, our company adopts the aim of creating a working environment that values the talents and experiences of each individual, respects differences and allows each employee to participate in the ideas and opinions of each employee.
Creating and maintaining a fair working environment where employees are not subjected to discrimination and ill-treatment is among our priorities.
An ethics committee is in place in accordance with the principles of confidentiality to identify any actions that have the potential for discrimination and maltreatment and to take the necessary measures. All our employee practices are based on individual ability and merit, regardless of race, religion, colour, age, sex, gender, nationality, sexual orientation, physical disability, seniority or other factors protected by law. These practices cover processes such as recruitment, promotion, transfer and rotation, training, disciplinary rules and termination of the employment relationship and form the basis of our other practices.
5.2 DETERMINATION OF PERSONNEL NEEDS, RECRUITMENT AND HR PLANNING
5.2.1Principles of Labour Force Planning
The following principles are taken into consideration in planning the labour force requirement:
a) Determining the human resources needed due to the planned production, auxiliary works and administrative works, in which organisational structure, in which title, status, qualification and number these human resources will take place, career management and backup by foreseeing the status of the positions that will become vacant for various reasons in the coming years (retirement, automation, etc.).
b) The new situation that the Company's working and expansion area should take in the direction of expansion or contraction in the future processes.
c) Whether the personnel structure of the company will meet the needs that will arise.
d) At the meeting held at the beginning of each calendar year with the department managers and the relevant Assistant General Managers, planning is made by forecasting the human resource needs that will be required for that year.
The selection, evaluation and placement of the personnel to be employed in the Company, the organisation of these activities and the necessary cooperation with the relevant departments are carried out by the HR department in a joint responsibility order.
5.2.2 Appointment Method and Authorisations
Appointment of personnel at various levels is made within the framework of the basic principles specified in the appointment regulation, within the authorisations specified below. Appointment procedures are determined by the Holding Executive Committee and implemented by the group companies.
a) Appointment of General Manager
It is proposed by the relevant member of the Board of Directors and approved by the Board of Directors.
b) Appointment of Assistant General Manager
The appointment is made upon the proposal of the General Manager and approval of the Board of Directors.
c) Manager Appointment
The appointment is made upon the proposal of the Deputy General Manager and the approval of the General Manager and the Board of Directors.
d) Chief Appointment
The manager and/or deputy general manager to whom he/she reports makes the proposal, and the appointment is made with the approval of the General Manager.
e) Expert Appointment
The chief, manager and/or deputy general manager to whom he/she reports makes the proposal, and the appointment is made with the approval of the General Manager.
f) Assistant Expert Appointment
The chief, manager and/or deputy general manager to whom he/she reports makes the proposal, and the appointment is made with the approval of the General Manager.
g) Foreman-Postman-Supervisor Appointment
The chief, manager and/or deputy general manager to whom he/she reports makes the proposal, and the appointment is made with the approval of the General Manager.
h) Compliance of Appointment Requests with Criteria
A new appointment, regardless of the level, is made after the HR Manager checks and approves that it meets the criteria.
5.2.3Career Pathways and Backup Plans
Boyçelik has a title structure with eleven positions as General Manager, Assistant General Manager, Manager, Chief, Specialist, Assistant Specialist, Officer, Foreman-Postman-Responsible Labourer. Career Maps have been prepared for specialist and higher positions and a reserve position has been assigned for each position.
Career Paths and Succession Plans are made in order to determine which positions can be assigned to these positions in case a position within the Boyçelik organisation becomes vacant for any reason (promotion, transfer, resignation, death, etc.). In the vertical replacement of a position, the previous position is taken as a hierarchical basis. If a position cannot be backed up vertically or if there are no suitable candidates for the vertically backed up positions, the horizontally backed up positions are taken into consideration. It is essential that the qualifications of the employees in the positions that can be transferred vertically or horizontally to the back-up position are in accordance with the minimum job qualifications required by the back-up position.
5.2.4Performance Management
A Performance Management System is implemented with a transparent approach to increase employee satisfaction and reward their success. This system includes a process to objectively and effectively evaluate the contribution of employees to the company's goals.
“Goals” and “Competences” form the basis of our approach. Our aim is to create a collaborative working environment by sharing company goals, priorities and corporate competences with all our employees.
Each employee, in co-operation with his/her unit manager, sets targets that will increase the success of the company and creates individual targets that will be effective in his/her area of responsibility. It is important that these goals are measurable and clear. At the same time, professional development goals are prioritised within the performance system.
Corporate competencies are evaluated with behaviour indicators and affect the final performance result. Our aim is to clearly convey expectations by observing the attitudes and behaviours of employees in accordance with the targets.
Interim evaluations are also carried out to increase the effectiveness of the Performance Management System. Providing effective feedback in the process of setting, monitoring and evaluating targets is an important factor determining the success of the system. Therefore, we attach special importance and care to this process.
Performance evaluation results are used in areas such as employee development plans, training needs analyses, wage studies and promotion/rotation decisions. These evaluations contribute to making plans for the development of employees, determining training needs, formulating wage policies and making promotion/rotation decisions.
The Performance Evaluation System proceeds in a one-year cycle.
In the first quarter of each financial year, employees meet with their team leaders to determine the targets and key performance indicators for that year.
In a follow-up meeting at the end of the second quarter of the financial year, the performance of the employees in the first half of the year is reviewed in accordance with the targets and indicators set and the current status is determined.
At the end of the financial year, the success of the employee's performance in the whole financial year is determined by analysing the performance of the employee at the level of the targets set and the performance indicators determined.
Forms to be used at all stages of performance evaluation will be provided by human resources.
Performance evaluation records and processes are subject to confidentiality.
The Performance Evaluation System plays a guiding role in matters such as wage management and promotion.
5.3 WORKING PRINCIPLES
5.3.1Working Days and Hours
In Boyçelik workplaces, as a rule, work is performed six days a week. Arrangement of forty-five hours of work in terms of days; weekly working days and hours are applied by distributing them to the days of the week in workplaces and/or workplaces/departments where continuous and shift work is required due to the nature of the work. The seventh day following the sixth day is a week holiday. The holiday day does not necessarily fall on a Sunday.
Depending on the situation of the workplace and/or the work, an equalisation process and compensatory work may be applied when necessary.
5.3.2In and Out of the Workplace
Personnel are obliged to comply with the working hours determined for the company and to be on duty within these periods. The necessary entry and exit are monitored by using a card reading system and these entries and exits are controlled by the Sap Time Management system created by the management. It is essential to follow up attendance duly. All employees must fulfil the requirements of the system when entering and leaving work.
5.3.3 Overtime
Overtime should only be worked in the event of work that cannot be completed within normal working hours. Care shall be taken to ensure that overtime work is performed at a frequency and duration that will not adversely affect the physical and mental health of the employee.
Overtime work paid on normal working days, overtime work paid, overtime work paid on week holidays and public holidays for white collars are paid according to the provisions of the relevant law and according to the provisions of the CBA for blue collars.
5.3.4Permits
All types of authorisations and the methods of their use are detailed in the relevant procedure.
5.4 FEES
5.4.1Wage Determination at Employment
a) The starting salaries of the General Manager and Deputy General Manager shall be determined by the Board of Directors.
b) The starting salaries of managers, supervisors, specialists, assistant specialists and civil servants shall be determined within the “Company Wage System” by taking into consideration the recommendations of the Human Resources department manager, with the approval of the Deputy General Manager and the approval of the General Manager, taking into consideration the Holding standards.
c) Blue Collar Skilled employees are paid a wage determined by the General Directorate in accordance with their experience, regional and workplace conditions, the wage band structure of the company and the CBA.
d) Teknik Lise ve Meslek Liseleri öğrenci stajyerlerine; stajları süresince ilgili yasada belirtildiği gibi en az net asgari ücretin %30’u ödenir. Devamlı istihdamları halinde o pozisyonun ücret sistemine geçilir.
e)Üniversite yaz dönemi stajyer öğrencilere asgari ücretin %30 u ödenir. Analist öğrencilere asgari ücretten, staja devam ettiği gün sayısı kadar ödeme yapılır.
5.4.2Fee Change
a) General Wage Increases
Wage increases for all personnel are made within the framework of the Wage Policy Principles.
b) Personal Wage Increases
Assignments from one post to another are announced at the appropriate time. Necessary salary changes are also made at the beginning of the following month or in the following salary increase period.
Salary and Additional Benefits
What kind of additional benefits will be provided to white-collar personnel from the determined service groups is determined by the General Directorate, taking into account the Holding Procedures and the recommendations of the HR Manager. CBA provisions are applied for blue collar personnel.
5.54.5.EDUCATION
5.5.1Training Policy
Trainings are provided both to respond to the development and learning needs of the personnel, who are the most important resource for the future of the company, and to acquire the knowledge, skills and new developments required by the organisation.
In order to ensure that the investments made are not wasted and to ensure the continuity of the knowledge and skill accumulation required in our workplace; the personnel who participate in the trainings to be given both in Turkey and abroad are expected not to leave the group companies for at least one year after attending these trainings. The personnel who leave the group companies within one year are asked to pay the cost of the trainings they attended.
For any training, the commitment in Article 19 and other articles of the employment contract applies. If these persons leave the group within one year following the training or if this leads to their dismissal according to Article 25/II of the Labour Code, the cost of the training will be charged to them. No such payment shall be requested from personnel who, through no fault of their own, are dismissed by the company due to a change of organisation within the group and/or company.
5.5.2Types of Education
a) Management Development Trainings for Senior Managers and Senior Manager Candidates
Participation in these trainings is possible upon the proposal of the General Manager, Assistant General Manager or HR department and with the approval of the General Management. This training for service groups (B, C, D, E) is carried out in well-known and reputable institutions in Turkey or in a foreign country. These trainings are coordinated by the Human Resources Department.
b) Technical Education Specific to Departments
These trainings are provided upon the proposal of the department managers, the review of the HR department and the approval of the training board. This training is given in-house by department managers or external trainer.
c) Other Personal Development Trainings
In this training, competency-based development activities are carried out in order to develop and update the expected employee profile in line with the main goals and strategies of the company. It is implemented by Human Resources.
d) On-the-Job Training
Before the personnel start working, training is planned and implemented according to Yİ-FR-046 046 “On-the-Job and Orientation Training Form” and then the start of work is given.
5.5.3Follow-up of Trainings
The Human Resources Directorate is informed in order to update the registry information of the participants of the training and to constitute the basis for the career plan.
Detailed information on training activities is included in the relevant procedure
5.6 GENERAL RIGHTS AND RESPONSIBILITIES
5.6.1Job Security and Occupational Safety
Personnel cannot be dismissed without a reason determined by laws and procedures. Personnel continue to work as long as their services are needed and useful to the company. It is the duty of the management to prepare the work environment in such a way that the personnel at all levels will not be exposed to any accident or occupational disease while working, whether in the office, production sites or construction sites, and it is the duty of the personnel to comply with all kinds of rules in this regard. The employer shall offer a suitable job to a person who suffers from a physical disability while working.
Employees have the right to work in a suitable and safe environment and to demand correction of non-conformities in these areas.
5.6.2 Resignation (Resignation Right)
Personnel may resign by notifying their line manager in writing. However, it is obligatory to comply with the notice periods. The resigning personnel has no right to claim severance and/or notice indemnity. The provisions of Labour Discipline and the situation of those who have special provisions in their service contracts are taken into consideration in case of resignation.
5.6.3Complaint Right
Personnel who believe that an injustice has been committed in the procedures applied to them have the right to complain to the competent authority. It is essential that complaints are made to the head of the department to which they are attached and finalised at this level. If no result is obtained from the complaints made in this way, the situation shall be communicated in writing to the relevant department manager. However; if the subject of the complaint is about the direct supervisor of the personnel, the petition can be submitted directly to the department manager; if the subject of the complaint is directly about the department manager, the petition can be submitted directly to the Human Resources Department.
5.6.4Right to Make Wishes and Suggestions
Personnel have the right to make a number of personal and professional wishes, to make suggestions to increase the efficiency and profitability of the company and to bring useful inventions to the business activities.
Blue-collar employees are given a suggestion award if their suggestions are accepted within the scope of suggestion awards.
Task Responsibility
Personnel are obliged to perform their duties in accordance with the provisions of the legislation in force and the instructions given by their manager and in accordance with the job descriptions assigned to them, completely and without delay. In cases where the personnel do not see clarity in the provisions of the legislation in force or in the instructions and are in doubt, they must apply to their senior manager.
5.6.5 Responsibility in Transactions
The General Directorate is primarily responsible for the work of all departments. It is obliged to give the necessary instructions and control in order to ensure that the works are carried out without interruption, on time and in a complete manner.
Department managers are primarily responsible for the work of their departments. They are obliged to give the necessary instructions and control in order to ensure that the work is carried out without interruption, on time and in full.
Managers at each level are responsible to the manager at the next higher level for the results of the work of the departments they manage.
Personnel are responsible for the work specified in their job descriptions;
a) Quality
b) Speed
c) Personally responsible for their cost and profitability.
In the event that a job is performed by more than one person, these persons are jointly responsible to the manager to whom they report.
5.6.6 Obligation to comply with instructions
As a general principle, personnel are obliged to fulfil the instructions of their superiors. However, the personnel are not obliged to fulfil the orders that may damage the profitability, productivity and reputation of the company or that are not in compliance with the relevant principles of the company and the provisions of the legislation. Nevertheless, if the orders are repeated by his/her superior, he/she has the right to apply to his/her superiors in writing and in hierarchical order. No criminal prosecution can be made against the personnel for exercising this right.
5.6.7Protection of Company Interests, Information and Tacit Information
Personnel at all levels are obliged to show the necessary prudence and effort while performing their duties; to take into account the principles of confidentiality, profitability and efficiency and to avoid any actions and transactions that may put the company at a loss.
All employees are obliged to keep all information, reports and figures related to the interests of the company such as technical, administrative, financial, commercial, etc. that they will learn as long as they work for the company.
Behaviour contrary to the provisions of this article shall be deemed to be grounds for termination of the employment contracts of the employees without compensation and for filing a lawsuit against them for compensation for the damage caused.
An employee who leaves the company or the group for any reason whatsoever cannot use this information in a business or workplace that will create competition for at least two years.
5.6.8 Responsibility for Complying with Procedures, Procedures, Instructions and Announcements
Personnel must act in accordance with the procedures, procedures, instructions and announcements approved and published by the company managers. Announcements to be made are published on e-mail, Boyçelik Portal and notice boards.
5.6.9Responsibility for Handover and Delivery
Personnel who leave their duties permanently or temporarily cannot leave their duties unless they hand over and deliver the money and monetary values, documents, tools and equipment that they are responsible for keeping and using.
If the company suffers any damage due to failure to fulfil the duty of handover and delivery, those who cause the damage shall be liable. The form and principles of handover shall be determined by the department managers.
5.6.10Codes of Ethics, Moral Values and Employee Rights
Accuracy and honesty are our prioritised values in all our business processes and relationships. We act in line with this principle in our relations with our employees and all our stakeholders. Our rules and values are explained in the Business Life and Corporate Ethics handbook, which includes ethical and moral values prepared for Boyçelik and Erciyes Anadolu Holding companies, and are shared with our employees by publishing on Boyçelik Portal and distributing handbooks.
Reported or detected rule violations may be referred by the Chairman of the Ethics Committee to the disciplinary boards of the relevant companies, taking into account their nature and effects, and may also be resolved within the relevant company without the participation of the Ethics Committee. As a result of the investigations, decisions such as warning, suspension and termination of the employment contract may be taken (without prejudice to other rights arising from the laws) against persons who disrupt the work order and working peace of the workplace and employees, exhibit behaviours that are not in accordance with the workplace working rules, business standards and generally violate the ethical rules set out in this booklet.(See Business Life and Corporate Ethics Handbook)
We endeavour to protect and manage the rights of our employees in accordance with existing legal regulations and labour agreements. We adopt the principles of respecting human rights and complying with international standards and support these principles through company policies; the protection of human rights is recognised as a fundamental priority. At the same time, the right of employees to collective bargaining and freedom of association are respected.
Within the framework of company values and principles, our code of ethics, which is shared with all our employees, is strongly encouraged and mandatory trainings are organised in this regard. In case any ethical doubts arise or any behaviour or practice contrary to the rules is observed, all our employees have the opportunity to report this situation or use our communication channels for consultation.
Our employees can report unethical situations they encounter at any time via the Ethics Line.
We endeavour to rigorously implement, monitor and report the requirements of the Personal Data Protection Law. Employees' personal information is kept in full compliance with the principles of confidentiality within the company; likewise, our employees act with the responsibility to respect the confidentiality of all technical information, including proprietary applications and information in our company's database.
5.6.11Employee Participation in Management
All practices for our employees are meticulously carried out in full compliance with the laws regulating labour life. Procedures for recruitment, promotion, transfer, rotation, performance management, training processes and other working models are determined in writing and strictly implemented.
Our Company emphasises the active participation and responsibilities of employees and encourages their involvement in decision-making processes, committees and projects. To this end, periodic meetings, year-end evaluation and information panels, annual goal setting workshops and performance evaluation meetings are organised.
In addition, the requests, notifications and suggestions of our employees are communicated through our employee representatives at locations and taken into consideration by senior management on platforms such as Occupational Health and Safety Board Meetings and Management Review meetings. In this way, consultation and participation with senior management is ensured.
Finally, our employees have the opportunity to communicate their requests, suggestions and opinions through platforms such as Ethics Line. In addition, development areas are identified by providing feedback through open communication practices and employee surveys through which they can communicate directly with senior management.
Employee Satisfaction Survey is conducted once in every financial year.
The Employee Satisfaction Survey is conducted at the end of the fourth fiscal year quarter by all employees filling in the forms created by the Human Resources department and dropping them into the collection boxes placed in specific and pre-announced areas.
The Human Resources department will share the forms at least 1 week before the day the survey will be completed.
No information regarding the identity of the employees filling in the shared forms will be requested. Survey participation will be completely anonymous.
In addition to rating style questions on the subjects that the questionnaire wants to measure, there will also be a free writing section where employees can submit their wishes, complaints, suggestions and criticisms.
Following the completion of the survey, the results of the survey will be analysed by the Human Resources department and a report on the results will be prepared and shared with the management.
A summary of the survey results will be shared with employees using a platform or notice boards that they can access.
Wish-Complaint Boxes, where employees can submit their wishes, complaints, suggestions and criticisms, have been placed in locations where employees can easily and anonymously access them in our company's offices, switchboards and all other facilities.
All boxes are locked and keys are kept by identified authorised persons.
The boxes are opened at the end of each month and the messages they contain are collected and recorded.
In the records received, the content of the message, in which box it is located and similar information is noted together with the date of collection.
A folder in which all records are brought together is kept by the Human Resources department.
The original messages from the boxes are kept for at least 1 year after recording.
In the areas where the boxes are placed, any practice that would reveal the identity of the employee who wants to convey a message is not allowed.
All collected messages are forwarded to the Human Resources department and evaluated. The actions to be taken as a result of the evaluation are announced to employees on a platform that they can easily access or by using notice boards.
5.7 DISCIPLINE
5.7.1Work Discipline
In order to ensure efficient and peaceful work in the Company, the personnel are required to act in accordance with the principles and procedures adopted by the Company and the provisions of the applicable labour legislation and to create a disciplined work environment.
Those who act and behave in a way that disrupts work discipline are given a disciplinary warning. These behaviours are taken into consideration in the success evaluation at the end of each year.
5.7.2Authority to impose disciplinary sanctions
Each person is authorised to be given a verbal warning by his/her first and second degree superior. The Disciplinary Board is authorised to give written warning and daily wage penalty.
The General Directorate and the Disciplinary Board are authorised to impose dismissal penalty.
5.7.3Disciplinary Board
The Company Disciplinary Board shall consist of four persons, two of whom shall be elected by the employer and two employee representatives of the trade union from the workplace. The employer appoints the Chairman of the Disciplinary Board. The Board convenes within three working days of the incident to discuss a matter referred to it. After examining the evidence and evaluating the written statements of all concerned, it shall render its decision within six working days at the latest from the occurrence of the incident. Decisions are taken by majority of votes. In case of equality, the chairman's vote shall prevail. The quorum of the Board and other principles are specified in the disciplinary regulation.
5.8 RESIGNATION AND DISMISSAL
5.8.1Separation from Work
All resignations and dismissals are made according to existing laws. There is no forced labour. Special provisions are reserved.
Resignation
Personnel may resign by notifying their manager in writing, but it is obligatory to comply with the notice period specified in Article 17 of the Labour Law No. 4857.
Dismissal
According to Article 17 of the Labour Law No. 4857 and Article 14 of the Labour Law No. 1475, dismissals requiring severance and notice pay and separations requiring severance pay according to Article 24 of the Labour Law No. 4857 cannot be made without the approval of the relevant member of the Executive Board or the General Directorate. The application is carried out by the Human Resources Manager.
It is essential to comply with the notice period for resignation or perfect termination of employment. The Company may, if it so wishes, pay the notice period in advance to the dismissed personnel and immediately terminate the relationship of the personnel with the Company.
Following the submission of the information of the personnel whose termination is requested;
a) The Human Resources Department requests all relevant records, documents, minutes and statements if the termination of the employment contract is requested by the company for valid or justified reasons. The personnel whose employment contract is requested to be terminated is asked for his/her defence regarding the reason for termination. If necessary, the personnel is given a certain time for this process.
b) The Human Resources Department evaluates the defence.
c) The Human Resources Department shall, if necessary, discuss this defence with the relevant manager or higher management.
d) In the event of a termination decision and in general, employees who are dismissed, voluntarily resigned or retired are asked to return the company assets in their possession in order to be dismissed from the workplace by paying their rights arising from the law. After the “Dismissal Form” (Resignation Form ?) issued by the Human Resources department employees is filled in completely and approved by the relevant department managers, it is sent to Human Resources for evaluation.
e) In case this form is not sent or sent incompletely; the personnel cannot be dismissed from the workplace and no accrual can be made about them.
f) The HR Specialist prepares the termination notice according to the type of exit and has the personnel sign it.
g) After the “Dismissal Form” is submitted to the Human Resources Department in full, the employee whose rights and receivables are paid to him/her is made to sign a “Release Form” and his/her relationship with the workplace is terminated.
h) In case the personnel refrains from signing, a report is made in front of the personnel with the signatures of two witnesses.
ı) The notice of termination, which the employee refrains from signing, is forwarded to the official residence of the employee through a Notary Public so that the notification can be officially made.
j) Upon request, a “Certificate of Employment” and other documents specified in the labour legislation shall be given to the personnel leaving the job.
k) The human resources officer conducts a “Departure Interview” with the departing personnel. Fills in the “Dismissal Evaluation Form”. He/she attaches this form to the registry file of the leaver. If deemed appropriate, the form is also forwarded to the relevant department manager and/or the General Manager.
l) The Human Resources officer ensures that the e-mail, user group and passwords of the relevant person are blocked after notifying the IT unit in writing (in mail environment) of the personnel information leaving the job.
m) If there are any embezzlements on the personnel who leave the job, these embezzlements, if any, are received by the Information Technologies unit and deducted from the person's embezzlement. In order for the personnel transactions to be completed on the Information Technologies side, it is completed by filling out the “BG-FR-030 Actions to be taken for the Personnel Leaving the Job” form containing user information.
Severance Pay and Notice Periods
Severance Pay: In case of termination of the employment contract in cases stipulated by the Collective Labour Agreement or the Labour Law; 30 days of dressed wage is paid for each year of seniority.
Notice Periods:
Seniority of staff;
2 weeks if less than 6 months
Between 6 months and 18 months, 4 weeks
6 weeks from 1.5 years to 3 years
8 weeks if more than 3 years.
Personnel Status Change
In the event of a change in the official or private status of the personnel (such as promotion, transfer, retirement, new education, change in the company assets owned, marriage, divorce, change of name or nationality, birth, death in the family, change of address, disability, significant and permanent illness), this situation is notified in writing to the Human Resources department employees. Human Resources employees process the information communicated to them in the registry file and attach the received document to the registry file.
5.9 CLOTHING / ATTIRE
Personnel should pay attention to their appearance and dress in general. Male personnel must take care to shave their hair and beard. Name badges must be worn by everyone. Especially our personnel, who have intense representation and hospitality duties, should act in accordance with our company image and show the necessary sensitivity to the subject.
5.10 IN-COMPANY TRIP
The trip to be made within the company for our dealers, suppliers and company officials who come as guests is made within the relevant procedure.
Disciplinary action will be taken against our responsible personnel for trips made without the knowledge of the management.
5.11 CHANGES
The changes needed in the procedure are notified to the Human Resources unit via UDF via EBA. The Human Resources department and the quality management unit make the changes in accordance with the format and take them to the approval authority and request approval. Approved new/additional items are published in their newly edited form and with a new number.
6 REPORTING AND TRANSPARENCY
The Company's human rights performance is declared annually in the Company Sustainability Report. Through this medium, commitments, activities and performance regarding human rights are announced to the public and all stakeholders.
7 SUPPORTING DOCUMENTS
EN-PR-017 TRAINING PROCEDURE
İS-FR-007 ON-THE-JOB AND ORIENTATION TRAINING FORM
İS-FR-004 WORK ACCIDENT NOTIFICATION FORM
İK-FR-005 TRAINING REPORT FORM
IS-TL-005 WORK SAFETY COMMITMENT
EN-TB-001 Internal and External Communication Plan
Sustainable Supply Chain Policy
1 PURPOSE
The purpose of the Sustainable Supply Chain Policy (hereinafter referred to as the “Policy”) is to define the principles for managing the supply chain operations of Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“) in order to maximise the profitability of the supply chain while minimising its environmental impact and maximising its impact on social welfare.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Policy Sustainability Policy
Employee Refers to company managers and employees.
Sustainability: In line with the United Nations definition, it means meeting our own needs without compromising the ability of future generations to meet their own needs.
Greenhouse Gas Emissions: It refers to the release of gases such as Carbon Dioxide (CO2), Methane (CH4) and Nitrous Oxide (N2O) into the atmosphere, which cause the sun's rays reflected from the Earth to be retained in the atmosphere and cause the Earth to warm up.
Supply Chain: It refers to the whole system of companies, people, technology, activities and resources that cover the movement of a product or service from the supplier to the customer and within this process.
3 SCOPE
This is politics;
Members of the Board of Directors of the Company,
Company managers and employees,
Companies and their employees from which goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 DUTIES AND RESPONSIBILITIES
4.1. Board of Directors
4.1.1. The Board of Directors is responsible for the supervision of the effective operation of the notification, examination and sanction mechanisms in cases of violations and suspicious situations that are contrary to the principles and principles set forth in the Policy.
4.2. Sustainability Committee
4.2.1. The Sustainability Committee is responsible for the formulation, implementation and updating of the Policy on behalf of the Board of Directors.
4.2.2. The Sustainability Committee is responsible for the follow-up of all strategies and projects created by the Company in line with its sustainability goals.
4.2.3. The Sustainability Committee is responsible for establishing the necessary communication channels for reporting violations and suspicious situations that are contrary to the principles and principles in the Policy and for examining the reported violations and suspicious situations.
5 APPLICATION PRINCIPLES
The Company prefers suppliers that work in accordance with sustainability principles. In supplier selection, the Company considers environmental performance, occupational health and safety standards, human rights and working conditions. It also encourages economic development by prioritising local and community-supported suppliers.
The company sets long-term goals in its supply chain strategies and adopts an approach that leads the way in generating and producing solutions to sustainability challenges.
The Company engages suppliers that invest in developing the knowledge and expertise of their employees and encourages its business partners to make similar investments. The Company expects its employees and the employees of its suppliers to adopt the principles of sustainable development in their routine work and to make all their decisions in line with these principles.
The Company ensures that its suppliers provide a healthy working environment for their employees, observe occupational health and safety practices and prioritise related issues in their activities.
The company procures all products and services in a way that adds value to the company. It prioritises the participation of suppliers that take actions in line with human health and the environment and treat their employees fairly on every platform.
The Company does not cooperate with the following organisations and does not work as a supplier:
Do not respect employee rights and do not comply with the legislation on this issue,
Practices contrary to the articles of the United Nations Global Compact (UNGC), of which we are a signatory,
Practices contrary to the articles of our Code of Ethics
Practices that are anti-competitive and do not comply with the existing legislation on this subject,
Does not respect the right of employees to organise as set out in the law,
Does not comply with the legislation on environmental impact, does not perform waste management,
The Company considers the sustainability of the materials and equipment used in production processes. Factors such as preferring materials that provide energy efficiency, are sourced from renewable resources, are recyclable and minimise environmental impacts are among the priority preferences in the supply chain.
The company works in coordination with technical departments in all procurement processes and prefers projects that will contribute to high efficiency and productivity.
The company gives preference to local suppliers and producers as long as they meet quality and sustainability requirements.
The Company expects its suppliers to comply with all laws and regulations regarding environmental impact, to regularly measure, monitor and improve their environmental impact.
The company prefers to have life cycle analyses of the products it purchases.
The Company aims to minimise waste generation in the supply chain and ensure that waste is managed effectively. It encourages sustainable waste management and circularity methods such as recycling, reuse and energy recovery and supports its suppliers in this regard.
The Company expects its business partners to respect human rights and provide fair working conditions. The Company uses effective control and monitoring mechanisms in the supply chain to protect the rights of employees, create safe and healthy working environments, and prevent child labour and forced labour.
The Company works to improve the sustainability of its supply chain by continuously seeking new solutions and innovative approaches. Working with business partners, the Company shares best practices and encourages the exchange of knowledge and experience to raise awareness on sustainability.
The Company continuously improves its communication with its suppliers. It works to increase the sustainability awareness of its suppliers.
The Company evaluates suppliers in terms of environmental and social aspects within the framework of the above principles. For this purpose, it adds the necessary criteria to the Supplier Environmental and Social Evaluation System and updates it regularly.
When selecting its suppliers, the Company applies the Supplier Environmental and Social Assessment process and assigns a rating according to our Supplier Environmental and Social Assessment System. This rating is one of the basic conditions for supplier selection. Existing suppliers are rated according to our Supplier Environmental and Social Assessment System at least once a year. Expects suppliers to continuously improve their environmental and social performance. In the event that practices incompatible with the values emphasised are detected, it requests corrective action from the relevant suppliers and monitors the process.
The Company takes initiatives to promote environmental responsibility.
The company promotes the development and diffusion of environmentally friendly technologies.
The company opposes all forms of corruption, including bribery.
The Company selects third party suppliers to the greatest extent possible to minimise the indirect environmental and social impact resulting from the purchase of goods and services.
The company encourages the development of supply chain management processes that enable sustainability levels to rise and improve.
The Company regularly monitors the level of indirect emissions related to suppliers (Scope 3 emissions) based on the principles of proportionality and materiality.
The Company complies with all applicable laws, legal provisions and standards in the countries in which it operates or is located and expects its suppliers to do the same.
The Company expects its suppliers to comply with the principles of the United Nations Global Compact and the core labour standards published by the International Labour Organization (ILO).
The Company expects its suppliers to prohibit all forms of child labour and forced labour in their companies.
The Company expects its suppliers to provide a work environment free from discrimination based on gender, skin colour, religion, nationality, political or other beliefs, ethnic origin, physical disability, age, sexual orientation and identity or other personal discrimination.
The Company expects its suppliers to respect the rights of their employees to form an employee representative body and to bargain collectively in accordance with relevant national laws.
The Company expects its suppliers to establish and implement an adequate occupational health and safety management system.
The Company expects its suppliers not to cause harmful soil alteration, water pollution, air pollution, harmful noise emissions or excessive water consumption that could significantly affect protected rights and legal interests.
Within the scope of supplier diversity, the company provides equal opportunities for various business enterprises to compete.
The Company makes an assessment according to the Supplier Environmental and Social Assessment System, reviews the business relationship with suppliers that go beyond the sustainable supply chain expectations, do not make efforts to compensate for nonconformities, and act incompatible with its priorities in this field, and suspends or terminates the business relationship in cases where no solution can be found.
The Company evaluates suppliers whose business relationship has been suspended or terminated due to Supplier Environmental and Social Assessment System performance or non-conformities detected, to improve their performance or eliminate problems before re-establishing a business relationship.
6 CONTACT
The Sustainable Supply Chain Policy has been announced to all current suppliers and is continuously and easily accessible through the corporate website.
7 NOTICE AND NOTIFICATION
Company Employees, Business Partners and all other parties outside the Company may submit their complaints and notifications regarding Policy violations to the Sustainability Committee verbally or in writing via e-mail.
E-mail: surdurulebilirlik@boycelik.com.tr
Address: O.S.B. 37th Cad. No:4, 38070 Melikgazi, Kayseri, Turkey
8 RUNNABILITY
This Sustainable Supply Chain Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Sustainable Supply Chain Policy will remain valid and in force until a new announcement is made.
9 SUPPORTING DOCUMENTS
EN-PL-004 ENVIRONMENTAL POLICY
EN-PL-008 HUMAN RIGHTS POLICY
EN-PL-009 HUMAN RESOURCES POLICY
EN-PL-006 CODE OF ETHICS POLICY
EN-PL-018 Anti-Bribery and Anti-Corruption Policy
Sustainability Policy
1 PURPOSE
1.1. The purpose of the Sustainability Policy (hereinafter referred to as the “Policy”) is to define the principles adopted by Boyçelik Metal Sanayi ve Ticaret A.Ş. (hereinafter referred to as the ’Company“) in its activities in the sector in which it operates in order to leave a better world and a better nature to future generations. Within the scope of Turkey's 2053 Net Zero targets, the Company agrees to support Turkey's transition to renewable energy and the development of clean energy infrastructure and believes that it has the responsibility to develop and improve business practices with a sustainability approach. Under this sense of responsibility, it integrates sustainability into the corporate culture.
1.2. In line with this purpose, the Company aims to be one of the leading organisations in the sector in terms of sustainability in Turkey and/or abroad with a sustainable company approach by setting targets in environmental, social, economic and corporate governance issues with the participation of all stakeholders. This policy has been established in order to ensure that Boyçelik's business model, all activities and business processes are in line with the sustainability strategy of the company; environmental, social and economic sustainability and corporate governance are observed in all activities of the company; and the sustainability goals, targets and performance criteria of the company are understood by all stakeholders.
2 DEFINITIONS
In this section, special terms and concepts used in policy are briefly explained as follows.
Company: Boycelik Metal Industry and Trade Inc.
Policy Sustainability Policy
Employee Refers to company managers and employees.
Sustainability: In line with the United Nations definition, it means meeting our own needs without compromising the ability of future generations to meet their own needs.
Greenhouse Gas Emissions: It refers to the release of gases such as Carbon Dioxide (CO2), Methane (CH4) and Nitrous Oxide (N2O) into the atmosphere, which cause the sun's rays reflected from the Earth to be retained in the atmosphere and cause the Earth to warm up.
Net Zero: Refers to the balance between the amount of greenhouse gas emissions produced by an organisation, community or country and the amount compensated or absorbed.
Zero Waste: Refers to the waste prevention approach that includes preventing waste, using resources more efficiently, reducing the amount of waste generated, establishing an effective collection system, and recycling waste.
Supply Chain: It refers to the whole system of companies, people, technology, activities and resources that cover the movement of a product or service from the supplier to the customer and within this process.
3 SCOPE
This is politics;
Members of the Company's Senior Management,
Company managers and employees,
Companies and their employees from which goods and services are purchased,
Persons and organisations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons, including customers with whom the Company has a commercial relationship (“Business Partners”)
covers.
4 DUTIES AND RESPONSIBILITIES
4.1. Senior Management
5.1.1. The Senior Management is responsible for the supervision of the effective operation of the Sustainability Committee and the Internal Audit Department, which are the reporting, examination and sanction mechanisms in case of violations and suspicious situations contrary to the principles and principles set forth in the Policy.
4.2. Sustainability Committee
4.2.1. The Sustainability Committee is responsible for the formulation, implementation and updating of the Policy on behalf of the General Manager.
4.2.2. The Sustainability Committee is responsible for the oversight of all strategies and projects created by the Company in line with its sustainability goals.
4.2.3. The Sustainability Committee is responsible for establishing the necessary communication channels for reporting violations and suspicious situations that are contrary to the principles and principles in the Policy and for examining the reported violations and suspicious situations.
4.2.4. The Sustainability Committee meticulously handles and analyses incoming complaints and notices. If a rule violation is detected as a result of the examination, it brings the matter to the agenda of the Internal Audit Department with the necessary evidence and documents. In addition, it takes the necessary measures and establishes the necessary mechanisms to prevent the same violation from occurring again.
4.3. Sustainability Committee/
4.3.1. The Sustainability Committee/ is responsible for the follow-up of all strategies and projects created by the Company in line with its sustainability goals.
4.3.2. The Sustainability Committee/ is responsible for reporting the Company's sustainability performance and management annually in accordance with international standards and frameworks.
4.3. Internal Audit Department
4.3.1. In the event that violations and suspicious situations that are contrary to the principles and principles in the Policy are detected, the Internal Audit Department makes objective assessments about situations that may result in Disciplinary Action in accordance with the provisions of the relevant legislation.
4.3.2. The Internal Audit Department is responsible for any employee who does not act in accordance with the Policy:
4.3.2.1. It is obliged to report about the employee to the Disciplinary Board and the relevant Unit Supervisor. The Disciplinary Board has the right and authority to take defence from the employee, initiate an investigation, suspend the employment contract, terminate the employment contract and exercise its rights in accordance with the Labour Law and applicable legislation.
4.3.2.2. Advise the Committee on the cases of ceasing to receive services from and terminating service contracts with non-compliant advisors, lawyers and financial experts.
4.3.2.3. Advise the Committee on the suspension, suspension and termination of commercial business relations with business partners who do not behave appropriately.
4.4. Employees
4.4.1. Company employees are responsible for ensuring compliance with this Policy, working in compliance with internal and external legislation and notifying the Sustainability Committee via the e-mail or address below in case of any behaviour, attitude, transaction, action, decision, activity or practice contrary to the Policy.
5 APPLICATION PRINCIPLES
Observing environmental, social and economic sustainability and corporate governance principles in all our activities,
The company aims to increase the installed capacity of green, clean and renewable energy.
The company aims to reduce energy consumption by using energy efficiency strategies and promoting energy management programmes.
The Company aims to consider environmental, social and economic impacts in all its activities and investments and to ensure that these aspects are taken into consideration in decisions regarding business activities.
The company aims to consider environmental and climate protection and the responsible use of energy and resources as part of its corporate goals and sustainable corporate strategy.
The company aims to continuously improve operational environmental protection, minimise environmental impact, conserve energy and resources and preserve the diversity of the natural habitat in an ecologically, economically and socially sustainable manner.
The Company aims to promote environmentally friendly and energy-efficient products and services and to minimise the use of energy and natural resources in all environmental impacts arising from the development of new products and services.
The Company aims to systematically identify the environmental and energy-related aspects of its activities, products and services, including waste, recycling, air, noise, energy, climate, soil and water.
The Company also analyses environmental and energy-related risks and aims to take measures to prevent problems that may adversely affect environmental or energy performance in operations and processes.
The Company aims to adopt a zero waste policy, minimise our waste and develop and implement circular economy solutions.
The Company aims to regularly monitor and improve its water management performance.
The Company aims to protect biodiversity and regularly analyse its impact and take measures to eliminate any negative impact.
The Company aims to take into consideration the expectations and priorities of its stakeholders when determining its goals and objectives.
The Company aims to align its strategies and investments with the United Nations Sustainable Development Goals (SDGs) and to contribute to the SDGs and their sub-goals, particularly Goals 7 and 13.
The Company aims to declare the management of its environmental, social and economic impacts at regular intervals in accordance with international standards and frameworks.
The Company aims to monitor and declare its performance in the field of occupational health and safety in order to provide a safe working environment for its employees, and to put improvement practices into effect by acting with the principle of continuous improvement.
Within the scope of combating climate change, the Company aims to calculate, monitor and declare our greenhouse gas emissions arising from its activities and to reach net zero by 2050.
The Company aims to carry out activities to make its supply chain sustainable and to audit its suppliers in this context.
The Company aims to contribute to the social and economic development of the local community in its fields of activity and to prioritise local employment and supply.
The Company aims to adopt the principles of equal opportunity, diversity and inclusion, and not to allow discrimination based on criteria such as mental or physical disability, religion, language, race, age, socioeconomic status, gender.
The Company aims to provide equal rights and opportunities to all employees in processes such as remuneration, reward, promotion and performance evaluation.
The Company aims to contribute to gender equality, provide equal opportunities for women in business life and increase women's employment.
The Company aims to support the participation of young people in employment and their competence development through training/internship programmes.
The Company aims to create a workplace culture that supports employee health, rights and satisfaction.
The Company aims to act honestly, transparently and accountably by observing Boyçelik's values and ethical principles.
The company aims to monitor the sustainability of its supply chain.
The Company aims to respect the representation and collective bargaining rights of its employees, not to tolerate bribery and corruption as emphasised in the Anti-Bribery and Anti-Corruption Policy, and to comply with all relevant legal regulations and ethical rules.
.
The Company aims to announce its Sustainability Policy to all employees and to the public and all stakeholders through digital channels and to make it accessible.
The Company aims to create platforms that will enable internal and external stakeholders to provide feedback and suggestions on the environmental, social and corporate governance performance of the organisation.
The company aims to make the sustainability perspective a corporate culture.
The Company aims to improve environmental protection and more efficient use of natural resources in its operations.
The Company aims to promote environmental awareness and involve employees in the development and implementation of sustainability and environmental programmes.
The Company aims to educate employees on compliance and best practices related to environmental and sustainability initiatives.
6 CONTACT
6.1. The Sustainability Policy has been announced to the Company's employees and is constantly and easily accessible through the corporate website.
6.2. The Company organises trainings to raise employee awareness on sustainability.
7 NOTICE AND NOTIFICATION
7.1. Company Employees, Business Partners and all other parties outside the Company may submit their complaints and notifications regarding Policy violations to the Sustainability Committee verbally or in writing via e-mail.
7.2. The Sustainability Committee meticulously handles and analyses incoming complaints and notices. If a rule violation is detected as a result of the examination, it brings the matter to the agenda of the Internal Audit Department with the necessary evidence and documents. In addition, it takes the necessary measures and establishes the necessary mechanisms to prevent the same violation from happening again.
E-mail: surdurulebilirlik@boycelik.com.tr
Address: O.S.B. 37th Cad. No:4, 38070 Melikgazi, Kayseri, Turkey
8 SANCTIONS AND PENALTIES
8.1. In case the Company fails to comply with this Policy, without prejudice to its right to indemnification for any damages:
It has the right and authority to take defence from the employee who does not act appropriately, to initiate an investigation, to suspend the employment contract, to terminate the employment contract and to exercise its rights in accordance with the Labour Law and applicable legislation.
It has the right to stop receiving services from non-compliant advisors, lawyers and financial experts and to terminate their service contracts.
It has the right and authority to stop, suspend and terminate commercial business relations with business partners who do not act in accordance.
8.2. The Company carries out these rights and authorisations through the relevant departments.
9 RUNNABILITY
This Sustainability Policy was put into effect with the Board of Directors Decision dated 01.10.2024. This Sustainability Policy will remain valid and in force until a new announcement is made.
10 SUPPORTING DOCUMENTS
EN-PL-004 ENVIRONMENTAL POLICY
EN-PL-008 HUMAN RIGHTS POLICY
EN-PL-009 HUMAN RESOURCES POLICY
EN-PL-018 Anti-Bribery and Anti-Corruption Policy
EN-PL-015 SUSTAINABILITY COMMITTEE WORKING AND ESTABLISHMENT PRINCIPLES POLICY
Ethics Booklet