Kordsa Ethics Line

The Ethics Hotline is a confidential tool that can be used to ask questions and/or share concerns about potentially unethical conduct. It is hosted by EthicsPoint and operated by NAVEX Global, an independent, third-party company. When you contact the hotline, your report will be documented in detail and addressed by Global Ethics and Compliance promptly, discreetly, and confidentially. You may speak or write a report in your own language. Reports may be made anonymously where permitted by law. Employees may also turn to their manager, the Global Ethics & Compliance team, or Human Resources Department to report their concerns.

Kordsa does not tolerate retaliation against an employee who cooperates with an investigation, raises a concern, or reports suspected misconduct in good faith. Raising a concern in “good faith” means being sincere in providing honest and accurate information, even if it is later found out the reporter was mistaken. We take retaliation claims very seriously – anyone found to have committed a retaliatory act will be subject to disciplinary action, including termination of employment and/or business contracts.

Once a report is submitted, the Global Ethics & Compliance team will review the details of such and notify the reporter on the status until the case is closed.

How to Submit a Report

Ethics Line

Online: kordsa.ethicspoint.com (desktop version) or kordsa-mobile.ethicspoint.com (mobile version)

Global Ethics Hotline Dialing Chart

Human Rights Management

We, as KORDSA, operate in compliance with Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises, International Labor Organization Fundamental Conventions and International Labor Organization Declaration on Fundamental Principles and Rights at Work in all countries we carry a business in, and abide with all laws and regulations and look after all rights of our employees by adopting the international declarations, fundamentals, conventions and principles that our country is a party to. Our approach towards our people is honest and fair. We commit to provide a non-discriminatory working environment for all, making sure that our people enjoy their employee rights fully and properly. We supervise suppliers and subcontractors in our value chain to protect human rights through Supplier Sustainability Evaluation Survey and our contracts.

Risk and Impact Assessment of Suppliers

Kordsa Code of Business Ethics and Human Rights Policy are embedded in the contracts with main suppliers. All employees of the subcontractors are informed by Kordsa officers on the codes of work and ethics on their first day at work.

Since there is no article that limits subcontractor employees to join a union, all employees are free to associate. Kordsa audits whether the subcontractor employees have social insurance, they are older than 18, and their wages and social insurance contributions are paid. In case of a complaint, our employees conduct on-site audit with the supplier.

Measuring and Evaluation

Employees who feel or suspect a violation of our fair working environment must notify their line managers, a member of Executive Leas Team, the Local Code of Ethics Consultant, the Global Ethical Compliance Officer or the Ethics Committee through ethics line. In addition, human rights risks and complaints in the company are audited both internally and externally by third parties.

Audit and Reporting

The Internal Audit Department conducts human rights and ethics policy compliance audits integrated in process audits. When there is a declaration regarding violation of Kordsa Code of Ethics, all necessary controls and audits are handled with the help of Local Ethical Compliance Officers.

After determining one or two topics regarding human resources each year, all our companies are audited by Sabancı Holding Audit Committee and Kordsa Audit Committee. A report is presented to the CEO and Board of Directors annually which includes ethics, human rights and human resources topics.

Audit findings are fed into Internal Audit Task Management (IATASK) system and supervisors are assigned tasks. At the end of a year, audit team conducts a follow-up visit in order to audit previous year findings and the actions taken. If the audit is successfully completed, all actions are closed in the system by audit team approval.

Consultation and Training

As Kordsa, we give ethics training to all our new employees. Like all employees, our security staff is also trained on code of ethics which include our human rights policies upon recruitment. These trainings are conducted through KEEP e-learning platform in Türkiye, Thailand, and Indonesia. In Brazil and USA, ethics trainings are done in classroom. Our CEO conveys awareness messages across all organizations in case an issue is spotted against ethics code depending on the type of the incident.

Anti-Corruption

Anti-corruption is one of the ten fundamental principles of the UN Global Compact that Kordsa signed in 2014. We keep an equal distance to all public agencies and institutions, administrative bodies, non-governmental organizations and political parties, without expecting any benefits, and realize our obligations with this responsibility in mind while carrying out all our operations and transactions.

We comply with Article 3.5.2 of the Corporate Governance Principles that stipulates, “Corporation shall be sensitive to its social responsibilities and comply with the regulations and ethical rules with regard to the environment, consumers, and public health. Corporation shall support, and respect internationally recognized human rights. Corporation shall fight against any kind of corruption including bribery.”

We published Kordsa Anti-Corruption and Anti-Bribery Policy, which is based on Turkish law, in 2015. The policy also covers our business partners including sub-contractors, consultants and lawyers. Our policy is communicated through our web site to all suppliers and other third parties we do business with.

Communication and trainings on anti-corruption in Kordsa cover all our employees in line with our Code of Business Ethics. Ethics Committee and Internal Audit functions monitor cases on anti- corruption, whistleblowing being also in charge of sanctions and reports to Sabancı Holding Ethics Committee.

Our measurement and monitoring mechanisms are Ethics Hotline and Internal Audit Department, Audit Committee and audits of Sabancı Holding. If a notification is made regarding corruption and/or bribery and the case is filed, Internal Audit Department reports the case to Audit Committee separately. Nevertheless, there’s no specific section regarding corruption and/or bribery in ethics reporting.

Prohibition of facilitation payments are clearly banned on clause 6.4. of our policy. Our employees cannot engage in any business relationship with family members, acquaintances or third persons that would result in mutual or unilateral benefits. They cannot earn or enable others to earn any money by engaging in trade, including trading securities on the stock exchange, using insider information. The rules mandate that employees cannot manage an enterprise, neither directly nor indirectly, and that they cannot work for a third person and/or organization during or outside of working hours in return for a certain fee or comparable gain.

Information Security Policy

Knowing that information assets are of great importance for business processes and functions, our Company aims to;

• Ensure confidentiality, integrity and accessibility of information assets and maintain continuity and control thereof,
• Restrict exposure to risks emerging from the loss, deformation or abuse of information assets and ensure compliance with laws and regulations,
• Protect information assets against all sorts of threats that may emerge either knowingly or unknowingly from inside or outside,
• Improve information security management systems constantly.

Our Information Security Policy covers all domestic and international Company personnel who use our Company's information or business systems, and all third parties who have access to such information or business systems regardless of their geographical location or business area, including independent service providers from which Kordsa receives services and their personnel.

Those using our Company’s information processing and information sources of our Company:

• Ensure the confidentiality, integrity and accessibility of the information that belongs to the Company in personal and electronic communication.
• Take security measures determined according to risk levels.
• Notify and report information security violations to the Information Security Incident Handler and take measures to prevent such violations.
• Do not transfer without authority internal information sources (announcements, documents, etc.) to 3rd persons.
• Do not use the Company’s information sources for activities that contradict to laws and ancillary legal regulations and national and international standards.
• Protect the confidentiality, integrity and accessibility of information that belongs to clients, business partners, suppliers or other third persons.

Our Company Management causes all employees of ours to receive awareness trainings with regards to Information Security issues in line with our Information Security Policy and ensures compliance therewith.

All employees support the Information Security Policy and principles and comply with the Information Security Management System (ISMS) policies, procedures and regulations that refer thereto.

Our Information Security Policy is in compliance with Sabancı Holding Code of Business Conduct.

Personal Data Process and Protection Policy

Please click here to download Personal Data Process and Protection Policy.

Please click here to download KVKK (the Law on Personal Data Protection in Türkiye) Data Subject Request Form*.

Please click here to download GDPR (EU Regulation for Personal Data Protection) Data Subject Request Form.

* Pursuant to the Law on Personal Data Protection, all applications to Kordsa-Data Controller shall be submitted in Turkish by the data subject.

Sanctions and Export Controls

Operating in several countries, we attach great importance to compliance with complex trade sanctions and export control laws and regulations, which basically prohibits the import, export or re‑export of certain products to or from certain countries or parties. We ensure compliance with such sanctions and export controls in accordance with our internal policies and procedures which are prepared in line with the policies and procedures issued by H.Ö. Sabancı Holding A.Ş. on sanctions and export controls.