Human Rights Policy

PURPOSE

As Efesan Group; in parallel with the sustainability understanding, creating a modern and respectful work environment for human rights, transferring the approaches and principles in the field of human rights, ensuring and encouraging our employees, customers, suppliers, business partners and all other stakeholders we are related to to be sensitive to human rights and to act within the framework of these principles.

 These values are at the core of our mission and we believe that all employees, customers and stakeholders should be treated with dignity and respect, regardless of their background, identity or beliefs. In this policy, which is designed to ensure that fundamental human rights are supported in all company activities by contributing to our company’s sustainability steps, we commit to act for the benefit of our country and the world by conducting all our activities within the framework of the Universal Declaration of Human Rights and the United Nations (UN) Global Compact.

SCOPE

This policy applies to all employees, contractors, consultants, interns and partners of Efesan Group. Everyone is expected to comply with this policy and to conduct their activities on behalf of Efesan Group in line with this policy. Efesan Group is also committed to working with joint venturers, suppliers and third parties that support the principles in this policy or adopt similar policies in their own businesses. This Policy shall enter into force upon the approval of the Board of Directors as of the date of publication and its validity period shall continue as long as the Policy remains in force.

RESPONSIBLE

Prepared by       : Strategy Unit (Human Resources Department and Sustainability Department)

Approved by     : Board of Directors

Published by     : Human Resources Directorate

BASIC PRINCIPLES, COMMITMENT AND IMPLEMENTATION GUIDELINES

We recognize that human rights are universal and indivisible and we are committed to promoting and protecting them in all aspects of our operations.

Our Human Rights Policy outlines our commitment to

1. Commitment to Human Rights:

Efesan Group is committed to respecting and promoting human rights as set out in the Universal Declaration of Human Rights and relevant international and national laws. This commitment extends to all aspects of our operations.

2. Working Conditions, Remuneration and Fringe Benefits:

Efesan Group conducts its operations in compliance with applicable laws on wages, working hours, overtime and fringe benefits. Efesan Group and its subsidiaries’ wage policy and personal rights are established in a competitive manner according to the sectoral and local labor market and in accordance with the terms of the applicable collective bargaining agreements. We conduct our operations in compliance with applicable laws on wages and working hours. We provide our employees with opportunities to develop their talents and potential and to make progress.

3. Diversity, Equality and Inclusion

At Efesan Group, we value the diversity of the people we work with and the contributions they make. We believe that a diverse and inclusive workplace is essential to foster innovation, creativity and growth. Our Diversity, Equality and Inclusion policy is designed to ensure that all employees, regardless of background, have equal opportunities to succeed. We have a deep-rooted commitment to fair treatment and equal opportunity and will not tolerate any form of discrimination or harassment. We are committed to creating and maintaining workplaces free from discrimination or harassment on the basis of race, color, religion, sex, gender, gender identity, sexual orientation, national origin, age, disability or any other status protected by applicable law.

This policy covers:

• Diversity We actively seek to create a workforce that reflects the diversity of the communities we serve and values different perspectives, experiences and ideas.
• Equality We are committed to providing equal opportunities and support for all employees, ensuring that everyone has the tools and resources they need to thrive.
• Inclusion: We strive to create an environment where every individual feels valued, listened to and empowered to contribute to their full potential.

Efesan Group;

Sustainable Development Goals in our work areas and all our business processes;

• Gender Equality
• Decent Work and Economic Growth
• Reducing Inequalities
• Industry, Innovation and Infrastructure

and in this way we aim for an inclusive socially livable world.

Throughout the value chain, we are guided by the principles enshrined in the Universal Declaration of Human Rights.

– All employment decisions are made based on qualifications and business needs without regard to race, color, religion, gender, gender identity, sexual orientation, national origin, age, disability or other protected characteristics. We work to raise awareness on this issue and lead this process with our management team.

• Efesan Group provides all employees with a safe and healthy, clean and clean working environment that meets or exceeds current occupational safety standards.
• Efesan Group attaches importance to cooperating with organizations with a fair, equitable and flexible structure. It sets an example with its Diversity, Equality and Inclusion practices and supports all its stakeholders to adapt to this process.
• We adopt the concepts of “Diversity”, “Equality” and “Inclusion” in our communication language and apply them in our business processes and aim to be a pioneer in social awareness with this language structure.
• Efesan Group and its subsidiaries aim to be an organization that supports continuous, inclusive and sustainable economic growth and creates productive and appropriate working conditions by adopting the principles of Diversity, Equality and Inclusion
• Our employees may submit their questions or concerns regarding this policy to the Human Resources Department or the Human Resources Managers of the relevant company. All complaints are handled in a confidential and objective manner.

Implementation and Compatibility

• We have established clear procedures and guidelines to ensure the effective implementation of these policies. These include
• Training and Awareness: Provide regular education and training programs to raise awareness of Diversity, Equality and Inclusion issues and equip employees with the knowledge and skills to promote an inclusive workplace.
• Reporting and Accountability: Establish mechanisms to report violations of these policies and commit to taking prompt and appropriate action in response to concerns raised.
• Continuous Improvement: Regularly review and update our policies and practices to reflect best practices and emerging trends in Diversity, Equality and Inclusion.

We are committed to maintaining a workplace that not only complies with legal requirements, but also exemplifies the highest standards of ethical behavior. We believe that by adhering to these policies, we can create a more inclusive, equitable and fair environment for all.

4. Freedom of Association and Collective Bargaining:

Employees at Efesan Group respect the right to join trade unions and participate in collective bargaining. Efesan Group is committed to constructive dialog with freely elected representatives of its employees represented by a legal trade union.

5. Safe and Healthy Workplace:

Efesan Group is committed to providing a safe and healthy working environment, aiming to fully ensure occupational health and safety at work and on the job. We will take all reasonable steps to prevent accidents, injuries and work-related illnesses and to comply with all relevant health and safety laws. Employees shall act in accordance with the rules and instructions set for this purpose and take the necessary precautions.

6. Zero Tolerance for Harassment and Violence

Efesan Group is committed to providing an environment that is safe for all employees and where there is zero tolerance for discrimination and/or violence arising from any form of harassment, including sexual harassment. Sexual harassment is unwelcome conduct of a sexual or other nature that causes a person to feel humiliated and/or intimidated and/or uncomfortable. The behavior may be exhibited as a condition of that person’s employment or may involve creating a hostile, intimidating or humiliating environment for the person subjected to it. Sexual or other forms of harassment may involve one or more incidents, and the actions that constitute harassment may be physical, verbal and non-verbal. Anyone who is subjected to and/or witnesses harassment (even if it does not escalate into physical violence or harassment) is aware that it is unwelcome behavior by the Efesan Group and a violation of this Policy. Recognizes that harassment can occur in unequal relationships (i.e. between a manager and a subordinate) and that the victim may be hesitant to report the alleged harasser, and therefore reminds the victim that he/she is on his/her side and that the company will support him/her if he/she decides to file a complaint, and that he/she will not experience losing his/her job, etc. If employees or other stakeholders learn about an ethical violation that may be contrary to this Policy, they use the complaint mechanism of this Policy.

The person or authority receiving a complaint of harassment;

– It immediately records the date(s) and time(s) of the event(s),

– Ensures that the victim understands the company’s grievance handling procedures,

– Keeps a confidential record of all discussions,

– Respects the victim’s choice to resolve the incident through company procedures and/or legal means.

In addition to the internal investigation, it is made clear to the victim that there is no obstacle to exercising their legal rights. At a minimum, the company is obliged to establish and operate a grievance mechanism with the above qualifications and make it open and accessible to its stakeholders. Include policies to prevent harassment in the Gender Equality Programs provided to all employees without exception throughout their company.

7.  of Expression

It adopts the principle of preventing any situation that may hinder employees from exercising their right to freedom of expression in the work environment, and provides the necessary tools and environments for employees to express themselves freely.

     8. No Child Labor

Efesan Group and its subsidiaries oppose the use of child labor, comply with relevant laws and regulations and act in a manner consistent with the Minimum Age Convention (ILO Convention 138). Except for training and apprenticeship programs approved by the authorities, no one under the age of 18 is employed.

It commits to develop procedures to avoid child labor practices and to carry out studies to evaluate the performance of the parties from which it receives services in this context within the scope of its commitments to international organizations.

9. Forced Labor

Efesan Group and its subsidiaries abide by the prohibitions against any form of forced labor, exploitation or slavery. Disciplinary measures based on physical and mental torture are not permitted. Our suppliers must also comply with this rule. Efesan Group is committed to complying with the Modern Slavery Act 2015, providing global support to eradicate slavery and human trafficking, and to the recognition and protection of human rights in all countries where we operate. Our Human Rights Policy is guided by the international human rights principles embodied in the Universal Declaration of Human Rights.

Employees and those working on behalf of Efesan Group are expected to comply with this policy and our code of ethics, which requires a commitment to ethical business practices and integrity at all times.

10. Career Development:

Efesan Group will offer training and career development opportunities to employees from diverse backgrounds.

Promotion and career development will be based on performance and merit, with a commitment to support underrepresented groups.

11. Retention and Engagement:

Regular surveys will be conducted to assess employee satisfaction and identify areas for improvement in diversity and inclusion. The company will provide resources and support for work-life balance, flexible working arrangements and other arrangements for retaining diverse talent.

EXPECTATIONS FROM OUR STAKEHOLDERS

• Our managers, employees and those acting on behalf of Efesan Group are required to comply with the Policy and to report violations or potential violations to their respective managers and/or through the company’s grievance channels.
• We expect our suppliers and business partners to act in accordance with the Policy.
• We encourage our stakeholders to provide feedback on the Policy.
• We encourage all employees, stakeholders and partners to adopt our human rights policy and take an active role in promoting human rights within our organization.

If you have any questions or require further information, please contact the human resources department.

0262 653 42 60

İnsan.kaynaklari@efesan.com.tr