Anti-Bribery and Anti-Corruption Policy
1. Purpose
The purpose of the Anti-Bribery and Anti-Corruption Policy (“Policy”) is to establish the anti-bribery and anti-corruption principles of Seyidoğlu Otomotiv Tamir ve Park İşletmeciliği Müşavirlik Hizmetleri A.Ş. (“Seyidoğlu Otomotiv”), which are also included in the Seyidoğlu Otomotiv Code of Business Ethics.
2. Scope
This Anti-Bribery and Anti-Corruption Policy applies to:
All Seyidoğlu Otomotiv employees, including the Board of Directors,
Companies from which we procure goods and services and their employees,
All individuals and organizations acting on behalf of Seyidoğlu Otomotiv, including suppliers, consultants, lawyers, external auditors, and other business partners.
3. Definitions
Corruption is the misuse of authority arising from one's position for the purpose of obtaining any kind of direct or indirect benefit.
Bribery is the act of offering, promising, requesting, or accepting an advantage—directly or through intermediaries—in order for a person to perform, cause to be performed, refrain from performing, accelerate, or delay an action related to their duty. It involves reaching an agreement with another person to act contrary to the requirements of their duty in order to provide benefit to themselves, the requesting party, or a third party related to such relationship.
Bribery and corruption may occur in many different forms, including but not limited to:
Cash payments
Political or other donations
Commissions
Social benefits
Gifts and hospitality
Other benefits
4. Duties and Responsibilities
The implementation and updating of the Anti-Bribery and Anti-Corruption Policy are under the authority, duty, and responsibility of the Board of Directors.
The Ethics Committee monitors whether Seyidoğlu Otomotiv activities are conducted safely and in compliance with legal regulations within their respective areas of responsibility.
In cases of non-compliance with policies, rules, and regulations, reporting, review, and sanction mechanisms must be established and implemented.
In addition, all Seyidoğlu Otomotiv employees are responsible for:
Complying with the policies determined by the Board of Directors,
Effectively managing risks related to their areas of activity,
Working in compliance with relevant legal regulations and Seyidoğlu Otomotiv practices,
Reporting any behavior, activity, or practice contrary to this Policy directly to the Ethics Committee through the Ethics Line (etik@seyidoglutedarik.com).
5. Companies and Business Partners Providing or Receiving Goods and Services
Companies and business partners providing or receiving goods and services must comply with the principles of this Policy and all applicable legal regulations.
Business relationships with individuals or organizations that fail to comply with these principles will be terminated.
5.1 Selection of Companies and Business Partners
During the selection process of companies and business partners providing or receiving goods and services, senior management evaluates criteria such as experience, financial performance, and technical competence, as well as their ethical standards and positive track record in this area.
Companies or business partners with negative intelligence related to bribery or corruption will not be engaged, even if they meet other criteria.
Before establishing any business relationship, the responsibility for conducting the necessary research and evaluations primarily lies with senior management.
5.2 Agreements with Companies and Business Partners
In agreements and contracts to be made with companies and business partners who meet the required criteria and have positive background information, the following conditions are included:
Full compliance with the principles stated in this Policy and other relevant regulations,
Ensuring that their employees understand and comply with these principles,
Providing periodic training to their employees regarding this Policy,
Regularly reminding employees of their reporting obligations and the Ethics Line, and encouraging them to report such situations if encountered.
Contracts will include provisions stating that failure to comply with these principles or the occurrence of any violation of this Policy will result in termination of the cooperation and existing agreements for justified cause.
6. Our Policies and Procedures
6.1 Bribery and Corruption
Seyidoğlu Otomotiv strictly opposes all forms of bribery and corruption.
Regardless of the purpose, the giving or receiving of bribes is strictly prohibited.
Business relationships with third parties seeking to conduct business with Seyidoğlu Otomotiv through bribery or corruption must not be maintained.
6.2 Gifts
A gift is an item given without requiring monetary payment, usually offered by individuals or customers with whom there is a business relationship, as a sign of appreciation or business courtesy.
Any gift offered or given by Seyidoğlu Otomotiv to third parties must be offered openly, in good faith, and unconditionally.
The principles regarding gifts that may be offered and their recording procedures are defined in the Gift Acceptance and Giving Policy included in the Seyidoğlu Otomotiv Code of Business Ethics.
The same principles apply to accepting gifts. Except for symbolic gifts with insignificant monetary value as defined in these principles, gifts must not be accepted.
Even in such cases, gift acceptance must not occur frequently, and accepted gifts must be reported by the recipient to the company’s HR department and senior management through their immediate supervisor.
6.3 Facilitation Payments
Individuals and organizations within the scope of this Policy must not offer facilitation payments to government officials to secure or expedite routine processes such as obtaining permits, licenses, or official documents.
6.4 Donations
Seyidoğlu Otomotiv employees may support charitable organizations through personal contributions independent of their work.
However, such activities fall outside the scope of the Seyidoğlu Otomotiv Donation and Aid Policy. In such cases, the principles included in the Seyidoğlu Otomotiv Code of Business Ethics remain applicable.
7. Accurate Record Keeping
The matters that Seyidoğlu Otomotiv must comply with regarding its accounting and record-keeping system are regulated by legal legislation.
Accordingly:
All accounts, invoices, and documents related to relations with third parties (customers, suppliers, etc.) must be recorded and preserved completely, accurately, and reliably.
No falsification or misrepresentation may be made in accounting or similar commercial records related to any transaction.
8. Training and Communication
The Anti-Bribery and Anti-Corruption Policy is continuously and easily accessible to Seyidoğlu Otomotiv employees via:
https://www.seyidoglutedarik.com
Training is an important tool to increase employee awareness.
In this context, the Human Resources Directorate and Accounting Department design training programs that require the participation of all employees.
9. Reporting Policy Violations
If there is an opinion or suspicion that an employee or a person acting on behalf of Seyidoğlu Otomotiv has acted in violation of this Policy, the matter must be reported to the Ethics Committee.
Seyidoğlu Otomotiv encourages a transparent and honest approach and supports any employee or person acting on its behalf who raises concerns in good faith. All reports are treated confidentially.
No employee shall be subjected to pressure or retaliation for reporting what they believe to be an ethical violation to the Ethics Committee.
Without the written approval of the Ethics Committee, no change can be made to the employee’s role or workplace due to such a report.
If the reporting person is subjected to such treatment, the matter must be reported to the Ethics Committee.
Companies providing goods and services and business partners must also regularly remind their employees about the Ethics Line and encourage them to report such situations.
10. Policy Violations
In cases that are or may be contrary to this Policy, the matter will be examined by the Ethics Committee. If inappropriate conduct is identified, the necessary sanctions will be applied.
Contracts made with companies providing goods and services or with individuals and organizations acting on behalf of Seyidoğlu Otomotiv will include provisions stating that if any behavior, attitude, or activity contrary to this Policy is detected, Seyidoğlu Otomotiv reserves the right to unilaterally terminate the cooperation or the existing agreements for justified cause.
These provisions will be applied without exception in case of a Policy violation.
11. Ethics Committee
The Ethics Committee, operating under the Chairman of the Board of Directors of Seyidoğlu Otomotiv, has been established to:
resolve conflicts of interest within the scope of the Seyidoğlu Otomotiv Code of Business Ethics,
evaluate reports regarding violations of ethical rules,
provide recommendations regarding procedures, methods, and practices to be followed in cases of ethical violations.
The Ethics Committee consists of the following members:
Chairperson – General Manager of Seyidoğlu Otomotiv San. ve Tic. A.Ş.
Member – Deputy General Manager of Seyidoğlu Otomotiv San. ve Tic. A.Ş.
Member – Human Resources Director of Seyidoğlu Otomotiv San. ve Tic. A.Ş.
Reports to the Ethics Committee can be submitted through the following email address: