ILESBUS Code of Conduct

İles Otomotiv Sanayi ve Ticaret A.Ş. Code of Conduct

Declaration of Compliance with Laws

İles Otomotiv Sanayi ve Ticaret A.Ş.  (İles) agrees to comply with the relevant legal requirements of the countries in which it operates,

the relevantinternationallegislation and rules of business ethics, as a minimum standard.

İles is committed to complying with all the rules and procedures described in the Code of Conduct Conduct, and the corporate policies

attached to this statement. Scope of Application İles’s Code of Conduct are binding on all managers and employees.

İles’s managers and employees, are required to read and sign the Code of Conduct.

A digital copy of the Code of Conduct is published on the official İles website and accessible to stakeholders. The relevant parties must

be informed of the changes to be made to this document and/or its annexes and their signed consent obtained.


  1- Human-Centered Approach Principle

  İles respects its employees as independent individuals and promotes an organizational structure based on mutual trust. Incompatible

  and disrespectful behavior is prohibited.2

        1.2 Employment

         ILES is committed to not discriminating against people in any way (religion, language, race, gender) with employment decisions,

         promotions and contract terminations, employing staff on the basis of their qualifications and merits and being just with its wage,

         side benefit and promotion policy.

        1.3 Employee Loyalty

        ILES measures employee satisfaction levels, continuously help staff develop their skills/competencies according to the company’s

        expectations and creates a working environment where staff motivation is kept high. Accordingly, it operates a fair wage and award

        and recognition policy with systematic and objective approaches.

        1.4 Work Environment

        Iles strives to create an environment where employees are respectful of each other and free from inappropriate verbal, visual or

        physical harassment. Inappropriate work environment includes violent language, verbal abuse, physical violence, sexual harassment

        or any action that implies offensive language or behavior. İles tries to create an atmosphere where employees can report violations

        with confidence, without fear. Each report is carefully examined and treated confidentially. It is strictly forbidden to retaliate against

        employees who cooperate in possible investigations in this context or report the incident.

       1.5 Prohibition of the Use of Illegal Products

        İles prohibits employees from working under the influence of drugs and alcohol. It aims to protect the well-being of its employees by

        fostering a safe and healthy work culture. İles prohibits all kinds of illegal drugs and illegal drug use. This includes the use, possession,

        manufacturing, distribution, transport, sale, offering free of charge and advertising of illegal products. If an employee shows signs of

        drug or alcohol use, such as significantly impaired judgement, deterioration of work performance or abnormal behavior, the company

        may ask the employee to submit their defense, with reference to the labor law and disciplinary procedures. Employees who violate this

        rule or refuse to cooperate without giving reasons will be subject to disciplinary action.

        1.6 Employee-Employee Relationship

         İles promotes the observance of human and workers’ rights and is committed to best practices to improve work conditions and

         occupational safety. Employees must interact with one another on the basis of respect, dignity and fairness, taking into account

         different cultural backgrounds of each individual, without allowing violence, harassment or abuse in the workplace. İles’s

         employees refrain from discrimination on the basis of race, religion, age, nationality, gender or any personal or social

         circumstances other than their qualifications and skills, especially taking into account disadvantaged people and their integration

         into work life. All employees are responsible for ensuring all types of health and safety standards in the workplace, providing for

         their own safety and the safety of those affected by their work.

        1.7 Employee-Customer Relationship

        Maintaining respect, dignity and fairness in their relations with customers, employees refrain from discrimination on the basis of

        race, language, religion, age, nationality, gender or other personal or social circumstances, especially taking into account

        disadvantaged people and their integration into work life. Concerning commercial activities, all employees must promote products

        based on objective standards. The Company engages in honest activities so as not to provide false or misleading information that

        could mislead its customers or third parties.

        1.8 Employee-Supplier Relationship

        İles’s employees maintain a lawful, ethical and respectful relationship with their suppliers. All procurement activities are conducted

        in full compliance with applicable law. İles’s employees are required to protect commercially sensitive information in relation to the

        terms and conditions set by the company for the purchasing chain. No İles employee may offer direct or indirect gifts, cash/non-cash

        inducements that could influence the decision-making process.

       1.9 Employee-Public Authorities and Officials Relationship

       İles’s employees maintain legal, ethical and respectful relationships with authorities and public institutions in the countries where they

       conduct business, in accordance with international regulations on anti-bribery and anti-corruption. As a general rule, no İles employee

       may offer, give, solicit or accept, directly or indirectly, gifts or donations, favors or bribes to any public authority or public official. Standard

       practices regarding gifts of intangible value are properly followed and evaluated by the company. It is the duty of every employee to inform

       himself/herself about company policies on bribery, and review local practices thoroughly, taking into account the interests and reputation

       of the company.


  2. Work Ethics and Anti-Corruption Principles

  İles employees are responsible for avoiding potential conflict situations in the workplace.

       2.1 Impartiality Principle and Compliance with Human Rights

       İles believes that everyone is equal free and have the right to live a dignified life.ILES respects fundamental human values that define the

       absolute ethical and moral threshold. Employees must act in accordance with the Code of Conduct and applicable laws.

       2.2 Harassment and Discrimination

       People of different race, gender, religion, language, nationality, ideology, age and/or disability should be able to work together harmoniously

       at İles. In this regard, ILES has no tolerance for violence. Sexual and psychological harassment is also a form of discrimination and is against

       the law. İles employees are responsible for being vigilant against harassment, towards employees of the institution, customers, suppliers and

       other stakeholders with whom they have a business relationship. They are obliged to report any harassment incidents they witness to the

       competent authorities. It is the duty of all employees to resolve work-related disputes in a civilized manner and to resolve them before they

       turn into something more serious and cause conflicts.

       2.3 Equal Opportunity and Compliance

       İles always applies the principle of equal opportunities for persons who might be susceptible to discrimination on the basis of their nationality,

       gender, sexual orientation, religion, language, nationality, world view, age and/or disability. From a moral and legal perspective, the Company

       offers equal employment and promotion opportunities to all, based on their individual qualifications and the requirements of their position.

       Management is responsible for preventing discrimination.

       2.4 Conflict of Interest

       Employees are responsible for remaining objective and avoiding situations that may lead to conflicts of interest. Employees must be careful about

       personal relationships and business dealings with family members, since commercial arrangements with persons with whom you have a personal

       relationship are prohibited. Employees must not engage in activities that could negatively impact the company or create a potential conflict of interest.

       Employees must also remember that investing in a company that does business with or competes with İles may be considered a conflict of interest.

       2.5 Justifiable Working Practices

       All processes must be carried out in accordance with company policies and procedures. All decision documents must be retained for as long as the

       required retention period, protected against damage or going missing and comply with applicable laws and administrative regulations.

       Employees must be polite and respectful to each other and not abuse their superior status to treat employees unfairly. If employees are given

       inappropriate work instructions that interfere with their impartial work performance, these must not be followed. An employee feeling personally

       aggrieved for not following a disallowed work instruction must contact Human Resources.

       2.6 Anti-Bribery and Anti-Corruption

       İles has a zero tolerance policy against corruption. It does not engage in any form of corruption, in particular bribery, money laundering, or financing

       of terrorism. İles understands that new methods may emerge in addition to known methods of corruption that have not yet been discovered but may be

       discovered on the back of advances in technology, and considers any conduct that may be described as corruption, whether or not specified in this

       document , to be a violation of its Code of Conduct.

       İles prohibits all acts of bribery or corruption. İles’s managers and employees, consultants, agents, persons acting on behalf of the Company cannot

       give or receive anything of value to/from anyone who can influence the Company with their decisions or persons who can influence them, particularly

       public officials, to manipulate their decisions about or attitudes towards the company.


  3. Occupational Health and Safety

  The occupational health and safety of the employees is priority for ILES. ILES arries out its activities in accordance with all occupational safety and

  health legislation. ILES tries to prevent and manage hazardous materials, disasters and risks. The company implements appropriate risk prevention

  measures before engaging in an activity. ILES provides a safe work environment for all employees by taking precautionary measures against potential

  risks. ILES provides a safe work environment by; (İ) designing a safe workplace, (ii) adapting its work processes to precautionary measures and safety

  rules, (iii) providing employees with protective equipment and (iv) holding regular training sessions. All employees adhere to regulations and company

  policies regarding cleaning and safety. Employees must report immediately to their respective supervisors after learning of practices or conditions that

  could lead to an accident. ILES works with an occupational health and safety expert in accordance with the legislation.


  4. Quality Management Systems Customer Satisfaction

  ILES implements a quality policy in order to meet the expectations of its customers. ILES maintains product quality at the desired level by standardizing

  products and processes striving for a sustainable quality approach. During the development and manufacturing of products, employees regularly check

  compliance with the requirements of product safety regulations. Employees should be careful in choosing suppliers. Once suppliers are selected,

  employees must ensure that these comply with Iles’s design and quality standards. Any concerns regarding the safety and quality of any parts sourced

  from suppliers must be  resolved in advance.  If an employee identifies an internal or external issue with occupational safety or product recall, they must

  notify the company immediately.


  5. Protection of Information

       5.1 Personal Data

       Employees must not record, store, keep, modify, rearrange or disclose, transfer, possess, make available, classify or prevent the use of any information

       that is considered personal data under the relevant law, which belongs to other employees of ILES, or other persons working in third-party institutions

       and organizations, unless acting as per a written authorization in accordance with company rules and requirements.

       5.2 Confidential Business Information

       Employees are responsible for protecting all information about their suppliers, customers and other business partners, besides company information.

       All employees are responsible for protecting company information and taking the necessary precautions. A security level is assigned to every piece of

       company data which dictates the nature of data safety measures. Employees may not disclose any information. The exchange of confidential information

       between organizations such as strategic partners or group companies is prohibited to secure a competitive advantage. All material/non-material gains

       from processes, eavesdropping, computer fraud and bribery using illegal and unethical methods are subject to disciplinary action.


  6. Recording and Provability of Decision-Making Documents

  All transactions conducted by ILES that may have an economic impact are clearly and accurately posted in the company’s balance sheets as a true and

  fair reflection of the transactions conducted and are made available to internal and external auditors. The financial data of ILES’s employees is entered

  into the company’s systems in a complete, clear and accurate manner so that they can demonstrate their rights and obligations in accordance with the

  regulations in force at the time. What must also be ensured is the accuracy and integrity of financial data that must be disclosed to the market in accordance

  with applicable legislation.


  7. Transparent and Fair Business Activities Principle

  ILES fully complies with the laws, regulations, tax regulations in its tax declarations, market announcements and reporting practices. It complies with all

  laws and regulations regarding customs tariffs. It keeps all company information about customs tariffs in a thorough and accurate manner, keeping it up-to-date

  at all times.

       7.1 Fair Trade

       ILES It knows the requirements of the fair trade act and consults its legal department, when necessary.

       7.2 Cooperation with Judicial Authorities

       In the event that competition authorities visit the company without prior notice or in the course of investigations, ILES actively cooperates with judicial

       authorities to accommodate legitimate data transfer requests and helps with investigative proceedings.

       7.3 Accounting and Taxation

       ILES maintains accurate books and records in accordance with the related law. ILES prohibits all types of forgery, alteration of documents and unfair

       acts that may misrepresent the nature of commercial activities.

       ILES files its tax returns and fulfills its payment obligations in accordance with the laws and regulations. It maintains a transparent relationship with the

       tax authorities and responds truthfully to enquiries for data transfer. ILES prohibits illegal tax evasion activities.

       Records of import/exports to/from any country must comply with institutional procedures.


  8. Environment

  ILES activities complies with all environmental regulations. ILES obliges all its employees to take all necessary care to keep the environment clean and

  prevent environmental pollution while continuing their activities.


  Reporting Violations

  Correspondences with İles are made by sending an e-mail to by mail or to the address Minareli Çavuş Mah. Mevzi Sok. No:36 Nilüfer/BURSA,

  enclosed in a sealed envelope stating the intended recipient, who is the Chair of the Board.

  All statements are handled and processed in secrecy. No retaliation of any form or nature can be made against any person who in good faith makes a claim,

  reports an act or suspicious situation that violates the Code of Conduct.