Institutional Social Responsibility Policy

1. Introduction

CCN Group and its Affiliated Companies aim to be a good corporate citizen in every work they perform.

CCN Investment Group and its Affiliated Companies are therefore determined to gather their current business principles under a framework policy called Corporate Social Responsibility (CSR). The principles included in this policy cover all areas of CCN Group and its affiliated companies’ activities and have been developed in accordance with relevant corporate governance rules and international standards, and continue to be reviewed and updated accordingly.

Our Board supports the principles set out in these rules and standards, and the objective of this policy is to transfer such support into a set of guidelines and standards that compose a common approach for the group and to provide a practical guide for our managers and employees in the area.

2. Conformity, Monitoring and Reporting

Conformity to this policy will be constantly monitored and will be subject to review of the Board.

Each local executive is responsible for ensuring that the principles set out in this policy are communicated to all employees, understood, and followed by employees to ensure compliance in their area of responsibility.

Employees who have reasonable suspicions that this policy has been violated in any way must report it through their own managers, senior management, or other mechanisms established within the Group for reporting of such violations. Employees may be reluctant to report their concerns due to fear of retaliation, and disciplinary measures will be imposed against any employee who behaved or attempted to behave with a threat of retaliation, revenge or mobbing to someone who has reported his/her concern with good faith.

The Board will not criticize any job loss resulting from adhering to the principles specified in this policy.

3. Business ethics Codes

3.1. General Declaration

These Code of Business Ethics sets out the standards expected from CCN Group and its Affiliated Companies’ employees in their internal and external relations with their colleagues, customers, stakeholders and third parties.

3.2. Basic Code Standards

We will conduct our business in all aspects with honesty, integrity and openness, with respect for human rights and considering interests of our employees, customers and third parties.

We will respect the legitimate interests of third parties whom we contact and relates during our work.

We will maintain the highest standards of integrity – for example, we will not promise more than we will reasonably deliver and will not make any commitments that we cannot or do not intend to keep.

3.3. Employee

We commit;

a) Developing a workforce with mutual confidence and respect, free from bullying and mobbing, where everyone feels responsible for our company’s performance and reputation,
b) Respect the rights, customs and traditions of individuals and their right to freedom of association and their right to decide whether to join a trade union; to negotiate in good faith with the appropriate representatives of our employees,
c) In line with our Equal Opportunities Policy, hiring, recruiting and promoting employees based on objective criteria and the qualifications and skills required by the work to be performed,
d) To maintain good communication with our employees through our information and consultancy procedures,
e) To provide appropriate training to our employees and to help them expose their potential,
f) To ensure that the privacy and confidentiality of our employees’ personal information are respected,
g) To reward our employees appropriately for their contribution to the success of the business,
h) Provide mechanisms where employees can raise legitimate concerns about corruption and ensure that no one is sacrificed for a report that has been submitted with good intention,
i) Provide employees with appropriate information and training to comply with these Codes and relevant policies,
j) We are committed to protecting our employees from third-party abuse that may damage their safety, health or well-being.

3.4. Work Integrity

We aim to establish strong relationships based on mutual confidence, understanding and respect with our suppliers, stakeholders, and other parties that we have contact with.

In these relationships, we expect the people we do business with to follow business codes in line with ours.

We will perform our activities in line with fair competition and valid regulations.

CCN Group and its affiliated companies shall explain and reflect the characteristics of the transactions behind accounting and other records and supporting documents.

No unregistered accounts, funds or assets will be established or maintained.

We will comply with applicable laws and regulations at every place we do business. Where necessary, we will use legal advice to comply with this commitment.

We will review and monitor our business risks, including social and environmental ones.

CCN Group and its Affiliates will not facilitate, support, tolerate or pass over money laundering in any condition.

3.5. National and International Trade

CCN Group and its affiliated companies will try to compete fairly and ethically under applicable competition and anti-monopoly laws, and we will not prevent others from competing fairly with us.

While undertaking global business, we will comply with all applicable export control laws and sanctions.

3.6. Personal Behavior

All employees are expected to act in accordance with the principles set out in this Code of Business Ethics.

Employees are expected to protect and not misuse company assets such as buildings, vehicles, equipment, money and purchase cards.

Employees are expected to use e-mail, internet, IP and telephones in line with the business objectives, in line with the principles contained in this Code and any kind of IP policies.

3.7. Bribery

None of employee of CCN Group and its affiliated companies or an enterprise working on our behalf shall give bribery, any improper payments, or accept any kind of improper payments, for any reason.

This is valid in transactions with government officials, any private company or person anywhere in the world. It is also valid when this payment is made or received directly or through a third party.

The group will ensure that adequate procedures are available to prevent the risk of bribery, and that they are effectively communicated and implemented.

3.8. Gifts, Honoring and Improper Payments

It is unacceptable to accept or give any honoring or gift with the purpose of influencing or affecting Business Decisions (that is, over USD 150). No employee should directly, or indirectly, offer, give, request, or receive incentives or other improper benefits for business or financial gain. In case an employee has any doubts whether accept or refuse an offer, such employee shall discuss this with manager or the Group HR Director.

3.9. Conflicts of Interest

While we respect the privacy of our employees, all our employees are expected to avoid activities and financial interests that conflict with their responsibilities towards CCN Group and its affiliated companies.

Group employee and counselors shall not try to make a profit for themselves or for others due to their positions in the company.

All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) shall be explained and discussed to the employee’s department manager.

Price-oriented information shall not be disclosed to third parties without authorization.

3.10. Confidentiality

The information gathered from any person during employment should not be used for any purpose other than individual gain or the purpose set for during their delivery.

Confidentiality will always be respected when confidential information is obtained during the business process.

3.11. Health and Safety

We are committed to creating and maintaining a safe and healthy work environment for our employees, customers and the community.

3.12. Environment

We are committed to improve the management of our environmental impact.

All employees are expected to comply with the local environmental management system and support the improvement of our environmental performance.

3.13. Customers

The Group is committed to provide its customers safe, return for money, high qualified, consistent, accessible and reliable services.

All employees are expected to act in a respectful and honest manner in all their relationships with customers and the general public, in accordance with the principles set out in this Code.
We will especially ensure and protect the welfare of vulnerable people in contact with our employees. Employees will be made aware that they are in a position of trust and that they must maintain the highest standards of personal conduct that reflect this trust that has been given to them at all times. Customer Service: Keeping our promise to our customers is one of our core values. Our commitment is to provide safe, reliable, customer-oriented, innovative and sustainable services.

3.14. Supply Chain

We purchase a wide range of goods and services that are essential for our business activities, and we rely heavily on our various suppliers to deliver our core services. Therefore, good business relationships with our suppliers are at the heart of our business success.

While we rely on obtaining and enduring competitive goods and services, we shall also strive to ensure that they are from sources that do not endanger human rights, safety or the environment.
We expect our suppliers to follow business principles consistent with ours.

We expect them to adopt and implement acceptable safety, environment, product quality, product management, labor, human rights, social and legal standards, in line with our Supplier Code of Conduct.

We will pay effort to work with our suppliers to develop long-term meaningful relationships that will serve for the benefit of both parties, with the goal of quality, environmental performance and sustainability of goods and services.

3.15. Social Participation

The activities of CCN Group and its affiliated companies are in contact with all community members every day, whether they are customers, neighbors, businesses or residents. We are committed to strengthening good relationships with the communities we work with and to establish social partnerships to make a positive change.

3.16. Implementation of Business Code of Ethics

The Corporate Management Board will be the highest decision-making body in the implementation of this Code.

Regarding the implementation or interpretation of the Corporate Audit Department Rules, all kinds of disputes that have not been settled in satisfactory manner, will be solved under the supervisory of Company top Management.

The Human Resources Department will implement rules and procedures to ensure full compliance with the Code. The Human Resources Department will take all necessary measures to ensure that all staff, suppliers, subcontractors and consultants know and understand the provisions of these rules and understand how to apply it in their working environment.

Employees who prefer to obtain more information than those provided by their managers can reach the Human Resources Department.

4. Employment

4.1. Equal Opportunities and Diversity Policy

The Board is dependent on equal opportunities both in the provision of public services and as an employer. The purpose of this policy is to ensure that all employees, customers, contractors and other persons in contact with CCN Group and its affiliated companies are treated equally and fairly and consistently all times.

Top management of CCN Group and its affiliated companies is responsible to provide the following:

a) Creating a working environment that is productive and healthy, promoting diversity and participation in the workforce;
b) To actively prove that diversity policy and practices of CCN Group and its Affiliated Companies are ensured;
c) Developing new applications to ensure the participation of employees, contractors and customers;
d) Prove continuous improvement in diversity and equal opportunities for everyone.

4.2. Legislation and Implementation Rules

This policy is in line with the current international legislation and the relevant codes of practice in the countries where CCN Group and its Affiliated Companies operate. CCN Group and its affiliated companies will follow this policy continuously to ensure compliance with the relevant sub-supporting regulatory requirements; however, the goal of CCN Group and its Affiliated Companies is to go beyond the requirements of the legislation where possible.

4.3. Recruiting

All recruiting will be carried out in fairness, equality and consistency for all candidates at all times. Recruitment practices will be inclusive and all barriers to employment will be eliminated under the relevant legislation.

4.4. Personnel Training

Guidance and training will be provided to staff to diversify awareness and equality to ensure that we are both an inclusive employer and a service provider.

4.5. Human Rights

The Human Rights Policy of CCN Group and its Affiliated Companies composes the ground of this section. All necessary definitions are included in the policy.

a) We will treat all employees fairly and honestly, regardless of where they work. All employees will have agreed terms and conditions and appropriate business skills training will be provided in accordance with local legislation or practice.
b) We will pay a fair fee, reflecting local markets and conditions. We will always meet any national minimum wage.
c) Working hours will not be excessive. These will comply with industry guidelines and, if applicable, national standards.
d) Employment should be freely chosen. Illegal child labor, compulsory or guaranteed labor will not be used and we will not tolerate illegal child labor.
e) We will comply with anti-discrimination laws in every country in which we operate.
f) We will not use physical punishment, mental or physical pressure, or verbal mobbing and will not tolerate the use of them. We have disciplinary procedures for any staff member whose behavior is below the required standard.