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Anti-Bribery  and Anti-Corruption

1. Purpose

The purpose of the Anti-Bribery and Anti-Corruption Policy (“Policy”) is to set forth the anti-bribery and anti-corruption policies of THERA Bilgi Teknolojileri Ticaret Limited Şirketi (“THERA”), which are also included in THERA Code of Business Ethics.


2. Scope

Anti-bribery and anti-corruption policy;

It includes all THERA employees, companies from which we purchase goods and services, and their employees, persons, and organizations (business partners) working on behalf of THERA, including suppliers, consultants, lawyers, and external auditors.

This Policy; It is an integral part of the Corporate Governance Principles approved by THERA General Manager and publicly disclosed, and the THERA Code of Business Ethics, the principles we undertake to abide by joining the United Nations' Global Compact, and Human Resources Practices.


3. Definitions

Corruption is the abuse of power, directly or indirectly, for any kind of gain.

Bribery is the provision, offer or promise of benefit, directly or through intermediaries, with the aim of making, doing, not doing, speeding up or slowing down a job related to the performance of one's duty; request or accept; is to provide an advantage to himself or to the party requesting it, or to someone else due to this relationship, within the framework of an agreement reached with another person in order to act contrary to the requirements of his duty by means of intermediary means.

Bribery and corruption can take place in many different ways, including:

  • Cash payments,

  • Political or other donations,

  • Commission,

  • Social rights,

  • Gift, hospitality,

  • Other benefits may be considered.


4. Duties and Responsibilities

Implementation and updating of the Anti-Bribery and Anti-Corruption Policy is the responsibility, duty and responsibility of the General Manager. In this context;

All THERA employees,

  • To comply with the policies determined by the Board of Directors,

  • To effectively manage the risks related to their field of activity,

  • Working in compliance with relevant legal regulations and THERA practices,

In case of encountering a behavior, activity or practice contrary to the Policy, it is responsible for notifying the Ethics Committee.


5. Companies and Business Partners Buying and Selling Goods and Services

Companies and business partners from which goods and services are purchased and sold must comply with the Policy principles and other relevant legal regulations, and work with individuals and organizations that do not comply with these are terminated.


5.1 Selection of Firms and Business Partners

During the selection of companies and business partners from which goods and services are bought and sold, the senior management takes into account criteria such as experience, financial performance, technical competence, as well as their ethical levels and having a positive history in this field. We will not work with companies or business partners who have negative intelligence about bribery or corruption, even if they meet the other criteria. In this context, the responsibility of carrying out the necessary research and evaluations before entering into any business relationship rests primarily with the senior management. The Audit Department evaluates whether the aforementioned matters are acted upon in its audits.


5.2 Agreement with the Firm and Business Partners

In agreements and contracts to be made with companies and business partners that have positive intelligence and meet other criteria;

Ensuring full compliance with the principles specified in the policy and other relevant regulations,

Employees to internalize these principles and act accordingly,

Ensuring that its employees receive training on the Policy periodically,

Conditions regarding regular reminders to its employees regarding their reporting obligations and encouraging them to report in case they encounter such situations are included. In case of non-compliance with these or a situation contrary to the Policy, the provisions regarding the termination of the work and the contracts in force with just cause are included.


6. Our Policies and Procedures

6.1 Bribery and Corruption

THERA is against all forms of bribery and corruption. It is absolutely unacceptable to take or give a bribe, regardless of its purpose.

The business relationship with third parties who want to do business with THERA through bribery or corruption should not be continued.


6.2 Gift

A gift is a product that does not require a monetary payment and is generally given as a thank you or commercial courtesy by people or customers in business relations.

Any gift offered or given by THERA to third parties must be offered publicly, in good faith and unconditionally. The gifts that can be given in this context and the principles regarding their registration are written in the Policy on Accepting and Giving Gifts in the THERA Code of Business Ethics.

The same principles apply to the acceptance of gifts, and gifts should not be accepted except for symbolic gifts of low material value, which are included in these principles. In addition, even if it is within this scope, the acceptance of gifts should not be frequent, and the top management of the company should be notified by the acceptor about the accepted gifts through his/her first supervisor.

6.3 Facilitation Payments

Facilitation payments are not offered in order to secure or speed up a routine transaction or process (obtaining permits and licenses, obtaining documents, etc.) with individuals and organizations within the scope of this Policy, with government agencies.


6.4 Donations

Some legal restrictions have been imposed on donations and aids with the Turkish Commercial Code and related legislation to which THERA is subject.

In the event that THERA employees support charities with the amounts they collect independently of their jobs, the principles in the THERA Code of Business Ethics apply.


7. Accurate Record Keeping

The issues that the THERA accounting and registration system has to comply with are regulated by legal regulations. According to this;

All kinds of accounts, invoices and documents related to relations with third parties (customers, suppliers, etc.) must be recorded and kept in a complete, precise and accurate manner, accounting or similar commercial records regarding any transaction must not be tampered with and the facts must not be distorted. .


8. Education and Communication

The Anti-Bribery and Anti-Corruption Policy has been announced to THERA employees and is constantly and easily accessible via the website.

Trainings are an important instrument for raising awareness of employees. In this context, training programs that require the participation of all employees are regularly implemented.


9. Notice of Policy Violations

If there is an opinion or suspicion that an employee or a person acting at THERA is acting in violation of this policy,  must be conveyed to THERA General Manager or the members of the Ethics Committee appointed by the General Manager. The issues related to THERA Code of Business Ethics are reminded periodically to THERA employees.

THERA encourages an honest and transparent approach; supports any employee or person acting on behalf of THERA who raises sincere concerns in good faith and keeps communications confidential. No employee can be subjected to pressure or punishment due to a notification he/she believes to be a violation of the Code of Ethics to the Ethics Committee.

If the notifier is exposed to such treatment, it is required to inform the Ethics Committee.

Firms or business partners from whom goods and services are purchased should also regularly remind their employees about the Code of Ethics and encourage them to make a notification in case they encounter such situations. This issue is also guaranteed by the contracts made.


10. Policy Violations

In cases that are or may be against the policy, the issue is examined by the members of the Ethics Committee and necessary sanctions are applied in case of inappropriate behavior.

In the contracts made with companies that buy and sell goods and services, or with persons and organizations acting on behalf of THERA, there are provisions stating that the works/contracts in force will be terminated unilaterally by THERA with a justified reason, in case it is determined that there is a behavior, attitude or activity contrary to the Policy, and the Policy. In the event of a violation, these provisions apply without exception.


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