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A. Integrity

Integrity and honesty are our primary values in all our business processes and relationships. We act with integrity and honesty in our relations with our employees and all our stakeholders.

B. Privacy

Classified information; Information belonging to THERA Bilgi Teknolojileri Tic. Ltd Şti (“THERA”) that may create a disadvantage in terms of competition information, trade secrets, financial and other information not yet disclosed to the public, information on personnel personal rights, and information about our employees, customers, and stakeholders It covers personal data and information that we are obliged to protect within the framework of "confidentiality agreements" with third parties.

As THERA employees; We take care to protect the privacy and private information of our customers, employees, and other relevant persons and organizations we work with. Protects confidential information about THERA's activities and uses this information only for THERA's purposes; We share this information with the relevant persons only within the specified authorities. While leaving our company, we have confidential information and documents, projects, regulations, etc., which we have due to our duties. We don't take the work out.

C. Conflict of Interest

As THERA employees, we aim to avoid conflicts of interest. Taking advantage of our current mission; We do not derive personal benefits from individuals and organizations with whom we have business relations, personally, through our family or relatives. We do not engage in business activities based on an additional financial interest other than THERA. We refrain from using THERA name and power, our THERA identity, for personal benefit.

In the event of a potential conflict of interest, we apply these methods when we believe that the interests of interested parties can be safely protected through legal and ethical methods. When in doubt, we consult our Manager or the Ethics Committee.

D. Our Responsibilities

In addition to our legal responsibilities; We take care to fulfill our responsibilities listed below towards our customers, colleagues, shareholders, suppliers and business partners, our competitors, society, humanity and on behalf of THERA.

1. Our Legal Responsibilities

We carry out all our current activities and transactions at home and abroad within the framework of the laws of the Republic of Turkey and international law, and provide accurate, complete and understandable information to regulatory institutions and organizations in a timely manner.

While carrying out all our activities and transactions, we are at an equal distance to all kinds of public institutions and organizations, administrative formations, non-governmental organizations and political parties without any expectation of benefit, and we fulfill our obligations with this sense of responsibility.

2. Our Responsibilities Towards Our Customers

We work with a proactive approach focused on customer satisfaction, responding to the needs and demands of our customers in the shortest time and in the most correct way. We deliver our services on time and under the conditions we promised; We approach our customers within the framework of the rules of respect, honor, justice, equality and courtesy.

3. Our Responsibilities Towards Employees

We ensure that employees' personal rights are fully and correctly used. We approach our employees honestly and fairly, and commit to a non-discriminatory, safe and healthy working environment. We make the necessary effort for the personal development of our employees, support them in volunteering for appropriate social and social activities with the awareness of social responsibility, and observe the balance between business life and private life.

4. Our Responsibilities Towards Our Partners

By giving priority to the continuity of THERA and in line with the goal of creating value for our partners; We avoid taking unnecessary or unmanageable risks and aim for sustainable profitability. We act within the framework of financial discipline and accountability, and we manage our company's resources and assets, as well as our working time, with an awareness of efficiency and savings. We take care to increase our competitiveness and invest in areas that have growth potential and will provide the highest return on the connected resource. In our public statements and to our shareholders; We provide timely, accurate, complete and understandable information about our financial statements, strategies, investments and risk profile.

5. Our Responsibilities Towards Our Suppliers/Business Partners

We act fairly and respectfully, as expected from a good customer, and show due diligence to fulfill our obligations on time. We carefully protect the confidential information of the people and organizations we do business with and our business partners.

6. Our Responsibilities Towards Our Competitors

We compete effectively only in areas that are legal and ethical, and we avoid unfair competition. We support the efforts to ensure the targeted competitive structure within the society

7. Our Responsibilities Towards Society and Humanity

Protection of democracy, human rights and the environment; education and charity work, the elimination of crime and corruption are very important to us. With the awareness of being a good citizen, it acts sensitively as a pioneer in social issues; We try to take a role in non-governmental organizations, public interest services, and appropriate activities on these issues. We are sensitive to the traditions and cultures of Turkey and the countries where we carry out international projects. Bribes or gifts, etc. in excess of the purpose. We do not provide or accept products and services.

8. Our Responsibilities Towards "THERA" Name

Our business partners, customers and other stakeholders trust us because of our professional competence and integrity. We try to keep this reputation at the highest level.

We offer our services within the framework of Company policies, professional standards, commitments and ethical rules, and we show the necessary dedication to fulfill our obligations.

We take care to provide services in areas that we believe we are and will be professionally competent, and we aim to work with customers, business partners and employees who meet the criteria of accuracy and legitimacy. We do not work with those who harm the morality of the society, harm the environment and public health.

We only express our company's views, not ours, in public and in areas where the audience thinks we are speaking on behalf of our Company.

In our relations with the press and on social media platforms, we act with the awareness that our views can be identified with our Company when expressing opinions about our duties and/or depending on our personal preferences.

When faced with complex situations that may put THERA at risk, we first consult with appropriate personnel, following appropriate technical and administrative consultation procedures.



A. Conflict of Interest Policy

It is essential that THERA employees stay away from situations that may create a conflict of interest. It is among the most important responsibilities of all employees that the company's resources, name, identity and power are not used for personal benefit, and to avoid situations that may adversely affect the name and image of the organization. The following principles of practice determine the situations of conflict of interest that Company employees may encounter in their private lives while performing their duties or due to their business relationships, and the principles to be applied in such cases.

Application basics


1. Activities That May Create Conflict of Interest

THERA employees are required to fully comply with the situations and principles specified below as activities that may create conflict of interest.  THERA does the necessary work to encourage its employees to comply with these principles.

I. Engaging in Activities That May Create a Conflict of Interest

  • Employees do not enter into a business relationship that provides mutual or reciprocal benefits with their family members, friends or other third parties in any way. For example, an employee with purchasing authority should avoid doing business with a supplier where a family member works. Exceptional cases are subject to the knowledge and approval of the Company's General Manager. In the same vein, THERA employees should be mindful of any conflicts of interest that may arise due to their close family members working for competitors.

  • Employees cannot gain any commercial interest by leaking any information about THERA from inside, and cannot cause others to gain benefits.

  • It is essential that THERA employees do not work for another person and/or institution for a fee or similar benefit, under any name, during or outside working hours, and do not engage in any work that requires them to be considered "traders" or "craftsmen" directly or indirectly._cc781905-5cde -3194-bb3b-136bad5cf58d_ However, if employees work outside of working hours for another person (family member, friend, other third parties) and/or for a fee or similar benefit;

  • Not creating a conflict of interest with their duties and practices in the company,

  • It does not create incompatibility with other business ethics rules and policies supporting these rules,

  • Does not adversely affect their ability to continue their duties in the company,

  • It is possible with the conditions of written approval of the Management as stated below.

  • For all positions reporting to the CEO/General Manager, it is given by the CEO/General Manager of the company, with the opinion of the Ethics Committee, following the opinion of his/her manager.

  • They can work in non-profit organizations and universities in social responsibility and charitable roles with the written approval of the management, provided that they do not disrupt their duties within the Company.

  • Managers who are in a position to make a hiring decision cannot hire their spouses, close relatives and relatives of these people.

  • Employees can make speeches and write professional articles on subjects that are not related to the company and its activities and are not contrary to its policies. The use of THERA name in these activities requires approval from the CEO/General Manager.

  • Managers cannot ask their employees to do political work or join a party. Employees can be active in any political party, individually and voluntarily. Employees  should pay attention to the following issues if they take part in any political party;

  • Employees taking part in any political activity should not create a conflict of interest with their duties and practices in the company. Employees cannot engage in any political activities during working hours and cannot take the time of their colleagues regarding these activities.

  • Employees cannot use the company name, position, title and company resources during their political activities.

  • Employees may make personal financial or moral aid and/or donations to third parties outside the Company, and may take part in charitable organizations. Employees take care not to become members of any clubs, associations or cooperatives by using the Company's name and position.

II. Misconduct

  • It is unacceptable for the employees to harm THERA by using their powers for their own and/or their relatives' benefit and out of the care expected from them.

  • Employees cannot directly or indirectly derive personal gain from the purchasing and sales activities of the Company and from all transactions and contracts to which it is a party.

  • Employees may not engage in acts and behaviors contrary to ethics, law and Company discipline.

III. Use of Resources

  • In the use of resources on behalf of the Company, the interests of the Company are taken into account.  Company assets, facilities and personnel cannot be used outside the Company, under any name, under any name and for the benefit of anyone. The principle of "saving in all matters" is applied by all personnel.

  • The correct use of resources for the benefit of the Company also requires the correct use of time. Company employees use their time well during business hours and do not spare time for their private work during business hours. Managers cannot assign employees for their personal work.

  • It is essential that special visitors are not accepted during working hours. Employees are required to complete the negotiations for compulsory visitors in a reasonable time in connection with the subject of the visit and in a way that does not hinder the work flow.

IV. Relations with Other Persons and/or Organizations with which THERA Has Commercial Relationships

  • Private business relations cannot be entered into with the Company's customers, subcontractors or suppliers and other persons and/or organizations with which the Company has a commercial relationship, no borrowed money and/or goods/services can be obtained for personal purposes, and other persons and/or organizations with which the Company has commercial relations. Borrowing money and/or goods/services cannot be given to individuals and/or organizations.

  • In relations with customers; Even in favor of the customer, a transaction cannot be made without the knowledge of the customer, the weaknesses of the customer cannot be exploited, and no profit motive can be sought by giving incomplete or incorrect information to the customer.

  • THERA personnel may not request gifts or imply any gifts from other persons and/or organizations with whom the Company has commercial relations; No gifts, money, checks, property, free vacations, special discounts, etc. cannot accept. Personal aid and donations cannot be accepted from any person or organization that has a business relationship with the Company. The Policy of Accepting and Giving Gifts is applied in relation to the subject.

V. Relations with the Media

  • In relations with the media, action is taken within the scope of the Company Communication Protocol.

  • Making a statement to any broadcasting organization, making an interview, seminar-conference, etc. Participation as a speaker is subject to the approval of the company's senior management. No personal gain can be obtained from these activities.

VI. Representing the Company

  • All kinds of wages to be obtained as a result of the duties performed in all kinds of associations, employers' unions and similar non-governmental organizations representing the company are donated to the relevant institution or the channels indicated by the relevant institution.

  • Payments made by third parties to the Company employee in return for seminar speaker fee or a similar service are similarly donated to the relevant institution or channels directed by the institution. These people, other than money, are given as a memory of the day and have symbolic value, such as awards, plaques, etc. they can get gifts.


B. Policy for Accepting and Giving Gifts

It is essential that THERA employees do not accept gifts or benefits that may affect their impartiality, decisions and behaviors, and do not attempt to provide gifts and benefits to third parties that may have such effects. The application principles defined below regulate the gift exchanges that the Company employees may have with third parties and organizations with which they have business relations and determine the principles to be applied in this regard.


Application basics

  1.  Company employees cannot accept any benefit or gift that may or may not affect their impartiality, performance and decision-making while working , with or without economic value.

  2. Company employees; They may receive and/or give gifts or agree to be subjected to a special application, provided that they are compatible with the corporate business objectives, comply with the current legislation, and that the public's knowledge of the gift will not put the Company in a difficult position.

  3. Provided that it complies with the conditions specified in the 2nd article above; Company employees can give and receive entertainment, treats and meals at acceptable standards in the business world, provided that they comply with the principles in the Company Authorizations Table. In seminars and similar organizations attended on behalf of the company, awards, plaques, etc., which have symbolic value and as a memory of the day, other than money. gifts can be received.

  4. The above-mentioned situations and other gifts, benefits, holidays, discounts, etc., other than money. Provided that it complies with the conditions listed in the 2nd article, if the total value of the gifts received is less than 500 TL, each calendar year and the person/institution giving the gift separately, they can be accepted without approval.

  5. Gifts or benefits that are indirectly or explicitly tied to a provision cannot be received.

  6. Receiving, giving or offering bribes and/or kickbacks is unacceptable under any circumstances.

  7. Company employees cannot accept free or borrowed money from subcontractors, suppliers, consultants, competitors or customers, and may not cover travel expenses, event expenses and similar payments.

  8. The company's senior management approves the gifts and promotional materials to be given to customers, dealers and other third parties with whom it has business relations. No separate authorization is required for the distribution of approved gifts and promotional materials.

  9. Provided that they comply with the conditions listed in article 2 above, the Company may accept suitable products and services as gifts, and products or services that comply with the buyer's culture and ethical values may be given as gifts, with the knowledge and approval of the Company's senior management.

  10. In exceptional cases where local cultural values require mutual gifts above the values determined in the company policy, these gifts can only be accepted on behalf of the Company and with the approval of the Company's senior management. In any case, the exchange of gifts should be made in accordance with the local culture.


C. Confidential Information Protection Policy

Information is one of THERA's most important assets to use to realize its vision. In this respect, it is the joint responsibility of all our companies and employees to use information effectively, to share it correctly, and to ensure the confidentiality, integrity and accessibility of information in this process. The following application principles; It defines confidential information for THERA and regulates the principles that employees must comply with regarding confidential information.


Application basics

Confidential information includes, but is not limited to, THERA's information that may create a competitive disadvantage, trade secrets, financial and other information that has not yet been disclosed to the public  information, personnel personal rights information, employee, customer and_cc781905-5cde- 3194-bb3b-136bad5cf58d_ covers the personal data of our stakeholders and the information we are obliged to protect within the framework of "confidentiality agreements" with third parties.

The principles to be followed regarding confidential information are listed below:

  • This information cannot be disclosed to third parties unless disclosure is required in accordance with Official Authorities and Legislation.

  • This information cannot be changed, copied or destroyed. Necessary measures are taken to ensure that information is carefully kept, stored and not disclosed. Changes on the information are recorded with its history.

  • Confidential files cannot be taken out of the institution. For confidential information that needs to be taken out of the institution, the approval of the information officer or senior management should be obtained.

  • Passwords, user codes and similar identifying information used to access company information are kept confidential and not disclosed to anyone other than authorized users.

  • Company confidential information cannot be spoken in dining halls, cafeterias, elevators, service cars and similar public places, and cannot be shared on social media accounts and mobile phone applications. It can only be shared by authorized personnel within the scope and time allowed by the Company Management on social media accounts and mobile applications belonging to the company.

  • Confidential information is classified according to their degree of confidentiality, it is clearly stated in the content of this information. Company personnel know the degree of confidentiality of the information they obtain due to their duties and act in accordance with this confidentiality. When there is hesitation in terms of confidentiality, a higher confidentiality class is acted upon and the relevant manager's opinion is sought when necessary.

  • If information is shared with third parties and/or organizations for the benefit of the Company, a confidentiality agreement is first signed or a written confidentiality commitment is obtained from the other party in order to ensure that the responsibilities of these individuals and organizations regarding the security and protection of the shared information are understood.

  • Reflecting the company policy and personal information of the personnel, wages, fringe benefits and similar personal information are confidential and cannot be disclosed to anyone other than the authorities. Personal information is sent to the individual. Personnel cannot disclose this information to others or pressure other employees to disclose information.

  • Act in accordance with the legislation on the Protection of Personal Data.

  • The above ethical obligations regarding confidentiality continue for the period after leaving the company for employees who leave the job for any reason.


D. Policy of Establishing and Maintaining a Fair Working Environment

THERA 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 that is compatible with all relevant laws and regulations. The following code of practice sets out the basic principles for establishing and maintaining a fair working environment at THERA.

Application basics

  1. Company practices comply with all applicable laws and regulations regarding employment and working life. Company employees also fulfill all legal requirements within the scope of their activities and act in accordance with legal regulations.

  2. THERA human resources policies and practices; recruitment, promotion-transfer-rotation, remuneration, rewarding, social benefits etc. ensures that all other practices are fair.

  3. It is unacceptable to discriminate among employees within the organization based on language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons.

  4. A positive and harmonious working environment that supports cooperation is created in the company, and conflict environments are prevented, enabling people with different beliefs, thoughts and views to work in harmony.

  5. The private life and personal spaces of the employees are respected.

  6. In addition to all kinds of immunities of the employees, physical, sexual and emotional immunities are also observed.

  7. Violation of the immunity of individuals in any way by physical, sexual and/or emotional harassment in the workplace or any place where they are due to work is against the law and ethical rules and this crime is not tolerated by the Company in any way. In this context, every measure is taken to ensure that employees work in a work environment where their physical, sexual and emotional immunity is protected.

  8. Violation of one's bodily immunity and/or sexual harassment without physical contact is defined as sexual assault/harassment. According to this; It is unacceptable to exhibit any behavior that can be considered within this definition.

  9.   carried out by one or more persons in workplaces for another person or persons, continuing systematically for a certain period of time, aiming to intimidate, pacify or remove from work; “Psychological Harassment in the Workplace” (Mobbing), which is a set of malicious, intentional, negative attitudes and behaviors that harm the personality values, professional status, social relations or health of the victim or victims, is also seen as one of the above-mentioned forms of harassment.

  10. It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.

  11. In order to ensure that the main activities it carries out do not have negative effects on the environment, THERA acts sensitively as a pioneer in its responsibilities towards society and humanity and takes all the measures required by the legislation. It improves the awareness and sensitivity of the employees in this regard.



Because THERA operates in international markets, company operations may be subject to different country laws and regulations. When there are question marks regarding the ethics of doing business in different countries, the established regulations in the country where the work is done should be followed first. If the monitoring of the regulations in the country and/or countries where the work will be carried out is of a nature that may create objectionable results in terms of the ethical values adopted by THERA, which will operate on the international platform, then we should try to find solutions within the ethical rules and procedures we have.



It has determined in detail the relevant policies and procedures, as well as the ethical rules on how we should behave and do our job. Compliance with these rules is the primary responsibility of all employees. In this direction, all THERA employees;

Acting in accordance with laws and regulations in all circumstances,

Reading the THERA Code of Business Ethics, knowing, understanding, internalizing and acting in accordance with the rules, principles and values in it,

Learning the general and business-related policies and procedures applicable to the company,

Consult your manager and human resources about potential violations related to yourself or others,

Promptly report potential violations of self or others; by basing their notifications on these matters on reliable sources, information and documents as much as possible) to their manager, human resources and/or the Ethics Committee or the General Manager, either verbally or in writing, on an anonymous or named basis,

Following the "Paths and Methods to Be Followed While Making Ethical Decisions", which is defined in order to assist in acting in accordance with the rules and in solving problems,

Cooperating with the Ethics Committee in ethical investigations, keeping information about the investigation confidential

has responsibility.


A. The Ways and Methods to Be Followed While Making Ethical Decisions

As you decide on an action plan, you should follow the steps below and ask yourself these questions:


1. Identifying the Event, Decision or Problem

  • Have you been asked to do something that you think might be wrong?

Are you aware of a potentially illegal or unethical business situation at your companies or business partners?

  • Are you trying to make a decision and have doubts about how to act in accordance with business ethics?


2. Think Before You Decide

  • Try to clearly define and summarize the problem or question

  • Ask yourself why it's a dilemma

  • Consider options, consequences for  and who might be affected

  • consult others


3. Decide on an Action Plan

  • Identify your responsibilities

  • Review all relevant facts and information

  • Consult appropriate company policies, procedures and professional standards

  • Evaluate risks and think about how you can reduce them

  • Try to create the best action plan

  • consult others


4. Test Your Judgment

  • Review ethical questions

  • Review your decisions within the framework of the company's core values

  • Be sure to consider company policies, laws, and professional standards

  • Consult others and consider their views within your planned action plan


5. Proceed with Determination

  • Share your decision with the relevant people along with your reasons

  • Share what you've learned and your success story with others


B. 4 Essential Questions to Consider


1. Is this activity/behavior in compliance with laws, rules and traditions? (Standards)

Does it meet professional standards?

Is it legal?

2. Is this activity/behavior balanced and fair? Would we be offended if the competitor firm (someone else) did it? (sense of justice)

Is it true for you?

3. Would our company and stakeholders be offended if all the details of this event were made public? (Feelings and ethical values)

Would you be in a difficult situation or embarrassed if others knew that you were behaving in this way?

Could it have negative consequences for you or your Company?

Who else might be affected (other employees within the company, you, shareholders, etc.)?

4. To what extent does "perceived reality" coincide with "objective truth"?

How was it reflected in the media?

What would a reasonable person think in the same circumstances?



THERA managers have additional responsibilities beyond the responsibilities defined for employees within the framework of ethics. Accordingly, managers;

  • Ensuring the creation and maintenance of a corporate culture and working environment that supports ethical rules,

  • To set an example for the implementation of ethical rules with its behaviors, to train its employees on ethical rules,

  • To support its employees in submitting their questions, complaints and notifications about ethical rules,

  • To provide guidance on what to do when he is consulted, to take into account all the notifications and to forward them to the Ethics Committee or the General Manager as soon as he deems necessary,

  • It is responsible for ensuring that the business processes under its responsibility are structured in a way that minimizes the risks related to ethical issues and to implement the necessary methods and approaches to ensure compliance with ethical rules.



Company top management; They are responsible for the effective implementation of the THERA-specific Code of Ethics or the THERA that they may create within this framework, and the creation of a culture in which it is supported.

The Code of Business Ethics and all relevant policies are reviewed, revised and documented with the recommendations of the Ethics Committee and announced to THERA employees with the approval of the General Manager.

  • In cooperation with the Ethics Committee;

  • To guarantee the confidentiality of complaints and notifications made within the framework of the Code of Ethics and to protect individuals after their notifications,

  • To ensure the occupational safety of the employees who make the notification,

  • They are responsible for ensuring that complaints and notifications are investigated in a timely, fair, consistent and sensitive manner and resolutely taking the necessary actions as a result of violations.




If the employees learn that the Company's Code of Business Ethics or the legal regulations to which the Company is subject are violated , they are obliged to report this to their direct managers first, and to the CEO/General Manager of the company if the situation is directly related to the manager.

Notifications made to the company are finalized and resolved in line with the company's internal functioning and procedures. Those who violate the Code of Business Ethics or Company policies and procedures will be subject to a variety of disciplinary sanctions, up to and including, if necessary, their dismissal.

Disciplinary sanctions will also be applied to those who approve or direct the inappropriate behavior and actions that cause breaking the rules, or who have knowledge of these issues and do not make the necessary notification properly. Also, there is no tolerance for those who show negative attitudes and behaviors towards people who make any complaints or notifications or assist during the investigation.

Intentional notifications that are false and/or slanderous are interpreted as a violation of ethical rules. The Company or the employee who has been lied to or slandered may apply to legal remedies separately, within the scope of the Turkish Penal Code, the Labor Law and the Law of Obligations and other relevant legislation.

A. Ethics Committee

Working under the THERA General Manager, the Ethics Committee was established to resolve conflicts of interest within the scope of ethical issues, to evaluate the notifications sent to it regarding violations of ethical rules, and to make recommendations regarding the ways, methods and practices to be followed in case of violations of ethical rules.


B. Working Principles of the Ethics Committee


The Ethics Committee carries out its work within the framework of the following principles:

  • It keeps the identity of notifications and complaints and those who make notifications or complaints confidential.

  • Anyone who makes a report to the Ethics Committee is under the protection of the Ethics Committee due to these reports, and they cannot be subjected to acts such as pressure, discrimination or mobbing.

  • The Ethics Committee conducts the investigation as confidentially as possible.

  • It has the authority to request information, documents and evidence related to the investigation directly from the unit available. It can examine all kinds of information and documents it has obtained only limited to the subject of investigation.

  • The investigation process is written down from the beginning. Information, evidence and documents are added to the report.

  • The minutes are signed by the chairman and members.

  • The investigation is handled promptly and the result is reached as quickly as possible.

  • Decisions taken by the Board are put into effect immediately.

  • Relevant departments and authorities are informed about the result.

  • The chairman and members of the board act independently and unaffected by the department managers and the hierarchy within the organization while performing their duties on this issue. They cannot be pressured or indoctrinated on the subject.

  • If the Board deems it necessary, it can seek expert opinion and benefit from experts by taking measures that will not violate the principles of confidentiality during the investigation.

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