DEHA TECH MAKİNA SANAYİ A.Ş. - Code of Conduct

DEHA TECH MAKİNA SANAYİ A.Ş.

CODE OF CONDUCT

1. MESSAGE FROM MANAGEMENT

Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., our reputation has been built on engineering excellence, technical expertise, integrity, quality, innovation, and long-term partnerships. Every project we undertake reflects our commitment to delivering safe, reliable, and sustainable engineering solutions while maintaining the highest ethical standards.

Applicable national and international laws
International Labour Organization (ILO) principles
United Nations Global Compact principles
Anti-bribery and anti-corruption legislation
Occupational Health and Safety regulations
Environmental protection legislation
International trade and export control regulations
Human rights principles
ISO Management System standards

General Manager
DEHA TECH MAKİNA SANAYİ A.Ş.

2. PURPOSE, SCOPE AND APPLICATION

2.1 Purpose

The purpose of this Code of Conduct is to establish the ethical principles, professional standards, and compliance requirements that guide all business activities carried out by DEHA TECH MAKİNA SANAYİ A.Ş.

Promote ethical decision-making across all levels of the organization
Establish common standards of professional behavior
Prevent unethical or unlawful business practices
Protect the rights, dignity, and safety of employees
Strengthen trust with customers, suppliers, shareholders, and society
Support sustainable business growth
Ensure compliance with applicable legislation and international best practices

2.2 Scope

Members of the Board of Directors
Executive Management
Department Managers
Engineers
Project Managers
Supervisors
Office Personnel
Production Personnel
Site Personnel
Temporary Employees
Interns
Consultants
Contractors
Subcontractors
Suppliers
Vendors
Service Providers
Business Representatives
Joint Venture Partners
Agents acting on behalf of DEHA TECH

2.3 Application

This Code applies to every business activity performed by DEHA TECH, including but not limited to engineering services, EPC projects, manufacturing operations, mechanical fabrication, electrical installation, instrumentation works, industrial automation, procurement activities, tender preparation, project management, construction sites, commissioning activities, maintenance services, international business development, customer relations, supplier management, logistics operations, digital communication, and financial activities.

2.4 Compliance with Laws

DEHA TECH is committed to complying with all applicable laws and regulations in every country where it operates...

2.5 Personal Responsibility

Every employee is personally responsible for reading and understanding this Code, completing mandatory compliance training, acting honestly and ethically, reporting suspected misconduct, cooperating with investigations, protecting the reputation of DEHA TECH, respecting company policies, and seeking guidance when uncertain.

2.6 Decision-Making Framework

Before taking any business decision, employees should ask: Is this action legal? Is it consistent with DEHA TECH values? Is it fair and honest? Would I feel comfortable explaining this decision publicly? Does it protect our company's reputation? Could it negatively affect our customers or business partners? Would I advise a colleague to make the same decision?

2.7 Commitment

Every individual working for or representing DEHA TECH shares responsibility for maintaining the Company's reputation through ethical conduct, professional excellence, respect for people, and compliance with applicable laws.

3. OUR CORE VALUES

3.1 Introduction

At DEHA TECH MAKİNA SANAYİ A.Ş., our values define who we are, how we work, and how we build long-term relationships with our customers, employees, suppliers, and business partners.

These values are the foundation of every engineering solution, manufacturing activity, EPC project, and business decision we make.

They guide our behavior, shape our corporate culture, and ensure that our success is achieved responsibly, ethically, and sustainably.

Every employee is expected to embrace these values and demonstrate them through daily actions and professional conduct.

3.2 Integrity

Integrity is the cornerstone of DEHA TECH. We conduct all business honestly, transparently, and ethically.

Be honest in all communications.
Keep promises and commitments.
Avoid misleading information.
Report unethical behavior.
Respect confidential information.
Act responsibly even when no one is watching.

Integrity builds trust, and trust is our most valuable asset.

3.3 Safety

Nothing is more important than the health and safety of our employees, contractors, customers, and visitors.

Zero tolerance for unsafe behavior.
Compliance with HSE regulations.
Continuous safety training.
Risk assessment before work.
Proper use of Personal Protective Equipment (PPE).
Incident reporting and investigation.
Continuous improvement of safety performance.

Our goal is simple: Zero Accidents – Zero Harm.

3.4 Quality

Quality is embedded in every stage of our work.

Engineering excellence.
Precision manufacturing.
Continuous improvement.
Compliance with international standards.
Customer satisfaction.
Defect prevention rather than defect correction.
On-time delivery.
Professional workmanship.

Quality is everyone's responsibility.

3.5 Customer Focus

Our customers are at the center of everything we do.

Professional communication.
Technical competence.
Reliability.
Flexibility.
Timely execution.
Responsiveness.
Continuous support.

3.6 Innovation

Innovation enables sustainable growth.

Think creatively.
Challenge traditional approaches.
Share ideas.
Learn continuously.
Adopt new technologies.
Improve efficiency.
Reduce waste.
Increase productivity.

3.7 Respect

Respect is fundamental to every relationship. We treat everyone with dignity regardless of nationality, race, gender, age, religion, disability, language, cultural background, position, or personal beliefs.

Harassment, discrimination, bullying, intimidation, violence, or abusive behavior will never be tolerated.

3.8 Accountability

Each employee is responsible for their decisions, actions, and professional conduct.

Delivering on commitments.
Taking responsibility for mistakes.
Learning from failures.
Reporting concerns.
Acting transparently.
Protecting company resources.
Supporting colleagues.

3.9 Teamwork

Success is achieved through cooperation across multiple disciplines.

Open communication.
Knowledge sharing.
Mutual support.
Professional respect.
Cross-functional collaboration.
Shared responsibility.
Collective success.

3.10 Sustainability

We recognize our responsibility to future generations.

Minimize environmental impact.
Improve energy efficiency.
Reduce waste.
Protect natural resources.
Support responsible sourcing.
Promote sustainable technologies.
Comply with environmental legislation.
Continuously improve environmental performance.

3.11 Professional Excellence

Professional excellence requires continuous learning, technical competence, and commitment to improvement.

Develop technical expertise.
Maintain professional certifications.
Participate in training programs.
Share best practices.
Improve engineering capabilities.
Follow international standards.
Pursue operational excellence.

3.12 Our Commitment

Our Core Values are more than guiding principles—they represent the culture of DEHA TECH and the expectations placed upon every employee and business partner.

By living these values every day, we strengthen our reputation, build lasting relationships, and deliver engineering solutions that create sustainable value for our customers and society.

"Engineering with Integrity. Delivering with Excellence."

4. BUSINESS ETHICS AND INTEGRITY

4.1 Our Ethical Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., ethics are the foundation of every decision, every project, and every business relationship.

Our reputation has been built through honesty, professionalism, technical competence, and responsible business practices. We believe that long-term success can only be achieved through ethical conduct and mutual trust.

Every employee, manager, director, consultant, contractor, supplier, and business partner is expected to uphold the highest standards of integrity in every aspect of business.

Ethical conduct is not simply compliance with laws—it is doing the right thing even when no one is watching.

4.2 Acting with Integrity

Act honestly in all business dealings.
Communicate truthfully and accurately.
Keep commitments and contractual obligations.
Treat others with fairness and respect.
Protect the Company's reputation.
Avoid misleading statements.
Never manipulate information for personal or commercial benefit.
Take responsibility for decisions and actions.

Integrity means choosing the ethical course of action, even when it may be difficult or unpopular.

4.3 Compliance with Laws

DEHA TECH operates in multiple industries and international markets. Accordingly, all business activities shall be conducted in full compliance with applicable:

National laws
International regulations
Industry standards
Customer requirements
Contractual obligations
Company policies

4.4 Honest Business Practices

Employees shall conduct business honestly and professionally. Examples of unacceptable conduct include:

Providing false information
Misrepresenting technical capabilities
Falsifying engineering calculations
Manipulating project documentation
Concealing defects
Issuing misleading reports
Altering inspection records
Misusing customer information
Creating inaccurate financial records

4.5 Transparency

Transparency strengthens trust. Employees shall ensure that communications with customers, suppliers, authorities, certification bodies, auditors, and colleagues are:

Accurate
Complete
Timely
Honest
Professional

4.6 Professional Behaviour

Employees are ambassadors of the DEHA TECH brand. Professional behaviour includes:

Respectful communication
Appropriate language
Responsible decision-making
Courtesy toward customers
Respect for cultural diversity
Maintaining confidentiality
Professional appearance where applicable
Responsible use of company resources

4.7 Ethical Decision Making

Before making any decision, employees should consider:

Is it legal?
Is it ethical?
Does it comply with Company policies?
Could it damage DEHA TECH's reputation?
Would I feel comfortable explaining this decision publicly?
Would this decision appear appropriate if reported in the media?
Does it protect our customers' interests?
Is it fair to all parties involved?

4.8 Respect for Stakeholders

Our business decisions consider the interests of:

Customers
Employees
Shareholders
Suppliers
Contractors
Local communities
Government authorities
Business partners
Future generations

4.9 Ethical Leadership

Managers have additional responsibilities. Every manager shall:

Lead by example
Promote ethical behaviour
Encourage open communication
Support employees seeking guidance
Prevent unethical conduct
Investigate concerns promptly
Never tolerate retaliation
Reinforce compliance through daily leadership

4.10 Responsibility to Speak Up

Employees are encouraged—and expected—to report suspected misconduct, unethical behaviour, safety concerns, fraud, or legal violations. Reports may be made to:

Immediate Supervisor
Department Manager
Human Resources
Compliance Officer
General Manager

Good-faith reporting is protected. No employee will suffer retaliation for raising genuine concerns.

4.11 Zero Tolerance

DEHA TECH maintains zero tolerance toward:

Fraud
Corruption
Bribery
Theft
Harassment
Violence
Discrimination
Falsification of records
Insider misconduct
Misuse of confidential information
Deliberate violation of Company policies

Violations may result in disciplinary action, suspension, termination of employment, contract termination, legal proceedings, or financial recovery actions.

4.12 Continuous Improvement

Ethics is a continuous journey. DEHA TECH is committed to:

Regular ethics training
Policy reviews
Internal audits
Risk assessments
Employee awareness programs
Continuous improvement of compliance systems

4.13 Our Commitment

Integrity is not only one of our values—it is the foundation upon which DEHA TECH builds every relationship, every project, and every success.

Every employee is expected to act honestly, responsibly, and professionally, protecting the trust placed in our Company by customers, colleagues, suppliers, and society.

By consistently applying these principles, we strengthen our reputation as a reliable engineering and industrial solutions partner committed to excellence, responsibility, and sustainable growth.

"Integrity in Every Decision. Excellence in Every Project."

5. HUMAN RIGHTS, EQUAL OPPORTUNITY & RESPECT IN THE WORKPLACE

5.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., we believe that every individual deserves to be treated with dignity, fairness, and respect.

We are committed to protecting internationally recognized human rights throughout our operations, supply chain, and business relationships.

United Nations Universal Declaration of Human Rights
United Nations Global Compact
International Labour Organization (ILO) Conventions
OECD Guidelines for Multinational Enterprises
Applicable national labour legislation

5.2 Respect for Human Dignity

Every employee has the right to work in an environment where they are respected and valued. DEHA TECH does not tolerate:

Physical abuse
Psychological abuse
Verbal abuse
Threats
Intimidation
Humiliation
Coercion
Violence
Retaliation
Exploitation

5.3 Equal Employment Opportunity

Employment decisions shall be based solely on qualifications, experience, competence, performance, skills, and business requirements.

Employment opportunities shall never be influenced by:

Race
Nationality
Ethnic origin
Color
Gender
Marital status
Age
Religion
Political opinion
Disability
Veteran status
Language
Sexual orientation
Gender identity
Any other characteristic protected by applicable law

5.4 Diversity and Inclusion

Innovation and engineering excellence thrive in diverse teams. DEHA TECH values different perspectives, cultures, experiences, and ideas.

Innovation
Problem-solving
Creativity
Customer relationships
Decision-making
Organizational resilience

5.5 Prevention of Harassment

Harassment of any kind is strictly prohibited. Examples include:

Offensive jokes
Insults
Bullying
Mockery
Humiliation
Sexual harassment
Unwanted physical contact
Inappropriate messages
Intimidation
Hostile behaviour
Cyber harassment

5.6 Workplace Bullying

Bullying undermines teamwork and employee well-being. Examples include:

Persistent criticism
Public humiliation
Deliberate exclusion
Threatening behaviour
Abuse of authority
Excessive monitoring
Intimidation
Deliberately withholding information

5.7 Child Labour

DEHA TECH strictly prohibits child labour. The Company complies with ILO Convention No. 138, ILO Convention No. 182, and national labour legislation.

5.8 Forced Labour

DEHA TECH prohibits every form of forced labour, bonded labour, prison labour (unless legally regulated), human trafficking, modern slavery, debt bondage, and involuntary overtime.

5.9 Freedom of Association

DEHA TECH respects employees' legal rights to join trade unions, form employee associations, participate in collective bargaining, and elect employee representatives.

5.10 Fair Compensation

Employees shall receive compensation that complies with applicable labour laws, employment agreements, minimum wage legislation, and overtime regulations. Unauthorized deductions from wages are prohibited.

5.11 Working Hours

Working hours shall comply with applicable labour legislation. Employees are entitled to daily rest periods, weekly rest days, annual leave, public holidays, and maternity/paternity rights where applicable.

5.12 Respectful Communication

Professional communication is essential to a healthy workplace. Employees shall:

Listen respectfully
Express opinions professionally
Accept constructive feedback
Resolve disagreements respectfully
Support teamwork
Avoid offensive language
Respect cultural differences

5.13 Employee Well-Being

DEHA TECH promotes safe working conditions, work-life balance, professional development, mental well-being, occupational health, continuous learning, and equal opportunity.

5.14 Responsibilities of Managers

Managers play a critical role in maintaining a respectful workplace. They are expected to:

Lead by example
Treat everyone fairly
Address inappropriate behaviour immediately
Encourage diversity
Support employee development
Listen to concerns objectively
Protect confidentiality
Prevent retaliation

5.15 Reporting Concerns

Employees who experience or witness discrimination, harassment, bullying, human rights violations, retaliation, or unethical behaviour should report the matter immediately through available channels.

Immediate Supervisor
Department Manager
Human Resources Department
Compliance Officer
General Manager

All reports will be handled confidentially, professionally, fairly, and without retaliation.

5.16 Our Commitment

Respect for people is one of DEHA TECH's core values. We believe that engineering excellence can only be achieved in a workplace built on trust, diversity, fairness, and mutual respect.

By protecting human rights and promoting equal opportunity, DEHA TECH strengthens its people, its projects, and its long-term success.

"People First. Respect Always. Excellence Together."

6. HEALTH, SAFETY & ENVIRONMENT (HSE)

6.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., protecting the health, safety, and well-being of our employees, contractors, customers, visitors, and the communities in which we operate is one of our highest priorities.

ISO 45001 Occupational Health & Safety Management System
ISO 14001 Environmental Management System
Applicable national legislation
Customer HSE requirements
International best practices

Every employee has the authority and responsibility to stop unsafe work.

6.2 Safety First

Work safely
Follow HSE procedures
Wear required PPE
Report unsafe conditions immediately
Participate in safety training
Support colleagues in maintaining a safe workplace

6.3 Individual Responsibilities

Follow HSE procedures
Use equipment correctly
Wear appropriate PPE
Maintain housekeeping standards
Report hazards immediately
Participate in toolbox talks
Cooperate during emergency drills
Refuse unsafe work
Protect coworkers
Report incidents honestly

6.4 Management Responsibilities

Lead by example
Promote a positive safety culture
Conduct regular safety inspections
Ensure risk assessments are completed
Provide adequate resources
Investigate incidents promptly
Correct unsafe conditions
Encourage employee participation
Ensure compliance with legislation
Continuously improve HSE performance

6.5 Risk Assessment

Hazards
Potential consequences
Risk levels
Control measures
Emergency actions
Required PPE
Training requirements

6.6 Personal Protective Equipment (PPE)

Safety helmet
Safety shoes
Protective gloves
Safety glasses
Hearing protection
Respiratory protection
Face shields
Flame-resistant clothing
Fall protection equipment

6.7 Safe Working Practices

Working at height
Confined space entry
Hot work
Electrical work
Lifting operations
Crane activities
Welding and cutting
Mechanical installation
Lockout/Tagout (LOTO)
Machine guarding
Excavation work
Pressure testing
Chemical handling

6.8 Stop Work Authority

Unsafe conditions exist
Safety procedures are not followed
Equipment is defective
Weather conditions create unacceptable risk
Required permits are missing
PPE is unavailable
Workers are not properly trained

6.9 Incident Reporting

Injuries
Near misses
Property damage
Environmental spills
Equipment failures
Unsafe acts
Unsafe conditions

6.10 Emergency Preparedness

Fire
Explosion
Medical emergencies
Chemical spills
Electrical accidents
Natural disasters
Gas leaks
Environmental incidents

6.11 Occupational Health

Occupational health monitoring
Medical examinations where required
Ergonomic workplaces
Fatigue management
Heat stress prevention
Noise protection
Air quality monitoring
Hygiene standards

6.12 Alcohol and Drugs

Working under the influence of alcohol or illegal drugs is strictly prohibited.

Consume alcohol during working hours
Report to work impaired
Possess illegal drugs on Company premises
Operate machinery while impaired
Endanger themselves or others

6.13 Environmental Responsibility

Preventing pollution
Conserving natural resources
Reducing emissions
Managing waste responsibly
Recycling whenever possible
Protecting biodiversity
Reducing energy consumption
Improving environmental performance

6.14 Waste Management

Separate recyclable materials
Dispose of hazardous waste properly
Prevent unnecessary waste
Store chemicals safely
Minimize material losses
Prevent contamination

6.15 Energy and Resource Efficiency

Reduce electricity consumption
Improve equipment efficiency
Reduce water usage
Minimize fuel consumption
Optimize logistics
Improve manufacturing efficiency

6.16 Contractor Safety

Company HSE procedures
Customer safety requirements
Applicable legislation
Site-specific safety rules
Permit-to-work systems

6.17 Continuous Improvement

Internal audits
HSE inspections
Incident investigations
Root cause analysis
Corrective actions
Preventive actions
Employee feedback
Safety observations
Lessons learned
Management reviews

6.18 Our Commitment

At DEHA TECH, safety is not simply a department—it is a shared responsibility and a fundamental value.

"Safety is a Value. Not a Priority. Values Never Change."

7. QUALITY & ENGINEERING EXCELLENCE

7.1 Our Commitment to Quality

At DEHA TECH MAKİNA SANAYİ A.Ş., quality is more than a business objective—it is a commitment that defines our reputation and drives our long-term success.

Safe
Reliable
Durable
Compliant
Innovative
Cost-effective
Delivered on time
Manufactured to international standards

7.2 Quality Culture

Take pride in their work
Follow approved procedures
Prevent defects rather than correct them
Identify opportunities for improvement
Report quality concerns immediately
Learn from previous projects
Share best practices

7.3 Compliance with Standards

ISO 9001 – Quality Management Systems
ISO 14001 – Environmental Management Systems
ISO 45001 – Occupational Health and Safety Management Systems
Applicable engineering codes and standards
Customer specifications
Contractual requirements
National and international regulations

7.4 Engineering Excellence

Apply sound engineering judgment
Follow recognized engineering standards
Verify calculations and designs
Ensure constructability
Consider safety throughout the design process
Promote innovation and efficiency
Document engineering decisions
Collaborate across disciplines

7.5 Design Integrity

Accurate
Complete
Verified
Reviewed
Approved
Traceable
Compliant with applicable standards

7.6 Document Control

Documents are current and approved
Revisions are properly controlled
Obsolete documents are removed from use
Records are maintained securely
Customer documents are protected
Confidential information is handled appropriately

7.7 Inspection and Testing

Inspection and Test Plans (ITPs)
Customer specifications
Applicable codes and standards
Project requirements
Quality procedures

Inspection activities may include incoming material inspection, in-process inspection, dimensional inspection, welding inspection, NDT, functional testing, FAT, SAT, and final inspection.

7.8 Non-Conforming Products

Stop further processing if necessary
Report the non-conformance promptly
Segregate affected materials
Investigate the root cause
Implement corrective actions
Verify effectiveness before release

7.9 Corrective and Preventive Actions

Root cause analysis
Lessons learned
Continuous improvement initiatives
Process optimization
Risk reduction activities

7.10 Customer Satisfaction

Understand customer needs
Deliver on commitments
Respond promptly to inquiries
Resolve issues professionally
Maintain open communication
Build long-term partnerships

7.11 Supplier Quality

Meet contractual requirements
Deliver conforming products
Maintain effective quality systems
Cooperate during audits
Report quality concerns promptly
Pursue continuous improvement

7.12 Competence and Training

Perform assigned tasks
Understand quality requirements
Apply company procedures
Use equipment correctly
Develop technical skills
Stay informed of industry developments

7.13 Innovation and Improvement

Improve quality
Increase efficiency
Reduce waste
Enhance safety
Improve customer satisfaction
Support sustainability

7.14 Responsibility of Every Employee

Perform work correctly the first time
Follow procedures
Report issues honestly
Protect company assets
Support colleagues
Respect customer requirements
Maintain professional standards

7.15 Our Commitment

DEHA TECH is committed to delivering engineering and industrial solutions that meet the highest standards of quality, safety, and reliability.

"Quality is not an act—it is our culture. Engineering Excellence is our promise."

8. ANTI-BRIBERY, ANTI-CORRUPTION & FRAUD PREVENTION

8.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., we are committed to conducting business with honesty, integrity, transparency, and fairness.

We maintain a Zero-Tolerance Policy toward all forms of bribery, corruption, fraud, embezzlement, extortion, facilitation payments, money laundering, and any unethical business practice.

8.2 Compliance with Anti-Corruption Laws

Turkish Anti-Corruption Legislation
OECD Anti-Bribery Convention
UK Bribery Act
U.S. Foreign Corrupt Practices Act (FCPA)
Local Anti-Corruption Regulations
Customer Compliance Requirements

8.3 Prohibition of Bribery

Bribery is strictly prohibited. Employees shall never offer, accept, request, promise, authorize, arrange, conceal, or ignore bribery.

A bribe may consist of:

Cash
Gifts
Loans
Discounts
Personal favors
Travel
Entertainment
Employment opportunities
Services
Donations
Sponsorships
Any other item of value intended to improperly influence a business decision

8.4 Facilitation Payments

DEHA TECH prohibits facilitation payments. Examples include:

Customs clearance
Permit approvals
Utility connections
Inspection scheduling
Visa processing
License issuance

8.5 Gifts and Hospitality

Reasonable business hospitality may support legitimate business relationships. However, gifts and hospitality must never influence—or appear to influence—business decisions.

Request gifts
Accept expensive gifts
Offer lavish entertainment
Accept cash or cash equivalents
Offer gifts during tender evaluations
Accept gifts in exchange for preferential treatment

Acceptable business gifts should be modest in value, infrequent, transparent, lawful, and properly recorded where required.

8.6 Conflict of Interest

Employees must avoid situations where personal interests conflict, or appear to conflict, with the interests of DEHA TECH.

Awarding contracts to relatives
Undisclosed outside employment
Personal financial interests in suppliers
Using Company information for personal gain
Accepting inappropriate gifts
Supervising close family members without disclosure

8.7 Fraud Prevention

Fraud is any intentional act designed to deceive another party for personal or organizational gain. Examples include:

Falsifying invoices
Manipulating expense claims
Misrepresenting project progress
Forging signatures
Altering inspection records
Creating false financial records
Payroll fraud
Procurement fraud
Theft of Company assets
Misuse of confidential information

8.8 Procurement Integrity

Procurement activities shall be conducted fairly and objectively. Supplier selection shall be based on quality, technical capability, safety performance, commercial competitiveness, delivery capability, financial stability, and compliance history.

8.9 Dealings with Public Officials

Interactions with government officials require the highest level of integrity. Employees shall never offer gifts, provide personal benefits, offer unofficial payments, circumvent legal procedures, or attempt improper influence.

8.10 Political Contributions

DEHA TECH does not make political contributions on behalf of the Company unless expressly authorized by the Board of Directors and permitted by applicable law.

8.11 Charitable Donations and Sponsorships

Charitable contributions and sponsorships shall support legitimate social initiatives, be transparent, properly approved, never be used to obtain improper business advantages, and comply with Company procedures.

8.12 Money Laundering Prevention

Conduct business only with legitimate organizations
Verify business partners where required
Report suspicious transactions
Maintain accurate financial records
Follow applicable financial controls

8.13 Third-Party Compliance

Suppliers, subcontractors, consultants, agents, distributors, and representatives are expected to comply with standards equivalent to those set out in this Code.

8.14 Reporting Concerns

Employees who suspect bribery, fraud, corruption, conflicts of interest, procurement irregularities, financial misconduct, or improper payments must report the matter immediately through established reporting channels.

8.15 Investigations

All reported concerns will be investigated fairly, confidentially, and objectively. Employees are expected to cooperate fully, preserve relevant records, provide truthful information, and maintain confidentiality throughout the investigation.

8.16 Consequences of Violations

Verbal or written warnings
Suspension
Termination of employment
Termination of contracts
Civil legal action
Criminal prosecution
Financial recovery actions
Reporting to competent authorities

8.17 Our Commitment

Integrity is the foundation of every business relationship at DEHA TECH. Sustainable success can only be achieved through honesty, transparency, accountability, and ethical decision-making.

"Integrity is our competitive advantage. Ethical business is our only way of doing business."

9. CONFLICTS OF INTEREST, GIFTS & BUSINESS HOSPITALITY

9.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., business decisions shall always be made in the best interests of the Company, our customers, and our stakeholders.

Employees are expected to perform their duties objectively, professionally, and without allowing personal interests, relationships, or financial considerations to influence business decisions.

9.2 What is a Conflict of Interest?

A conflict of interest exists when an employee's personal interests, financial interests, family relationships, or outside activities interfere—or appear to interfere—with the interests of DEHA TECH.

9.3 Examples of Conflicts of Interest

Awarding contracts to family members or close friends
Holding a financial interest in a supplier, customer, or competitor
Accepting employment with a competitor while employed by DEHA TECH
Using Company resources for personal business
Hiring relatives without following Company recruitment procedures
Supervising or evaluating the performance of close family members
Receiving personal commissions from suppliers
Using confidential Company information for personal investment decisions
Accepting personal discounts unavailable to other employees
Influencing purchasing decisions for personal benefit

9.4 Outside Employment

Conflict with Company interests
Affect job performance
Create divided loyalties
Use Company resources
Compete with DEHA TECH

9.5 Family Relationships

Participate in selecting relatives for employment
Influence supplier selection involving family members
Approve payments benefiting relatives
Supervise close family members without proper disclosure

9.6 Financial Interests

Ownership in suppliers
Ownership in subcontractors
Ownership in competitors
Personal investments creating undue influence
Hidden business partnerships

9.7 Business Gifts

Business gifts may be exchanged as a gesture of professional courtesy. However, gifts must never influence business decisions or create a sense of obligation.

9.8 Acceptable Gifts

Modest in value
Infrequent
Customary
Transparent
Lawful
Appropriate to the business relationship

Examples include promotional items, calendars, pens, technical publications, low-value commemorative gifts, and modest business meals.

9.9 Unacceptable Gifts

Cash
Gift cards
Personal loans
Luxury goods
Expensive electronics
Personal travel
Accommodation unrelated to business
Personal services
Gifts intended to influence a business decision
Any item prohibited by law or customer policy

9.10 Business Hospitality

Support legitimate business discussions
Reasonable in value
Transparent
Infrequent
Comply with Company policies
Comply with customer requirements

9.11 Travel Sponsored by Third Parties

Legitimate business purpose
Management approval obtained
Costs are reasonable
Transparency maintained

9.12 Supplier Relationships

Treat suppliers fairly
Maintain confidentiality
Evaluate suppliers objectively
Avoid preferential treatment
Protect competitive bidding processes

9.13 Customer Relationships

Communicate honestly
Respect customer confidentiality
Deliver accurate information
Avoid misleading statements
Never promise what cannot be delivered
Resolve concerns professionally

9.14 Use of Company Position

Requesting personal favors
Influencing government officials for personal benefit
Seeking preferential treatment
Using Company authority outside official responsibilities
Pressuring suppliers for personal gain

9.15 Disclosure Requirements

Potential conflicts of interest
Outside employment
Financial interests
Family relationships affecting business
Gifts exceeding Company limits
Situations that may affect impartiality

9.16 Reporting Concerns

Employees who become aware of undisclosed conflicts, improper gifts, procurement favoritism, abuse of authority, or unethical relationships shall report their concerns through established reporting channels. Reports will be handled confidentially and without retaliation.

9.17 Our Commitment

Maintaining independence, objectivity, and professional judgment is essential to DEHA TECH's reputation.

"Trust is earned through impartiality. Integrity begins with independent judgment."

10. CONFIDENTIAL INFORMATION, INTELLECTUAL PROPERTY & DATA PROTECTION

10.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., information is one of our most valuable business assets. Every employee has a responsibility to protect confidential information, intellectual property, customer data, engineering documentation, and digital assets from unauthorized access, disclosure, misuse, alteration, or loss.

Turkish Personal Data Protection Law (KVKK No. 6698)
General Data Protection Regulation (GDPR)
Customer Confidentiality Agreements
Non-Disclosure Agreements (NDAs)
Contractual Information Security Requirements

10.2 Confidential Information

Confidential Information includes any non-public information belonging to DEHA TECH or entrusted to us by customers, suppliers, or business partners. Examples include engineering drawings, AutoCAD files, 3D models, P&IDs, schematics, technical specifications, calculations, commercial offers, contracts, project schedules, financial information, software source code, and company databases.

10.3 Employee Responsibilities

Protect confidential information
Share information only with authorized persons
Verify recipients before sending documents
Lock computers when unattended
Protect passwords
Report suspected leaks immediately
Dispose of confidential documents securely
Follow cybersecurity policies

10.4 Customer Information

Employees shall never share customer drawings without authorization, discuss confidential projects in public, copy customer documents for personal use, upload files to unauthorized cloud services, or use customer information for personal benefit.

10.5 Supplier Information

Supplier information shall receive the same level of protection as Company information. Employees shall not disclose supplier pricing, commercial terms, manufacturing methods, technical documentation, intellectual property, or audit reports.

10.6 Intellectual Property

Engineering designs
Software
Databases
Technical know-how
Innovations
Process improvements
Trade secrets
Patents
Trademarks
Copyrights
Company logos
Product designs

10.7 Ownership of Work Product

Engineering designs, reports, software, calculations, procedures, manuals, technical documentation, and other work created during employment belong to DEHA TECH unless otherwise agreed in writing.

10.8 Information Classification

Public
Internal Use Only
Confidential
Highly Confidential

10.9 Data Protection

Accurate
Secure
Up to date
Accessible only to authorized personnel
Retained only as long as necessary

10.10 Cybersecurity

Use strong passwords
Enable MFA where required
Never share login credentials
Protect laptops and mobile devices
Install only authorized software
Report phishing emails immediately
Avoid suspicious websites
Keep systems updated
Follow IT security policies

10.11 Electronic Communications

Company email, messaging systems, and digital platforms are provided for business purposes. Employees shall communicate professionally, avoid offensive content, protect confidential attachments, verify recipients, and follow document retention requirements.

10.12 Social Media

Employees shall use social media responsibly. Without authorization, employees shall not speak on behalf of DEHA TECH, publish confidential information, share project photographs, disclose technical details, or damage the Company's reputation.

10.13 Artificial Intelligence (AI) and Digital Tools

Employees shall use AI and digital productivity tools responsibly. Confidential or customer-owned information shall not be entered into public AI platforms unless authorized. AI outputs must always be reviewed by qualified personnel before use.

10.14 Reporting Information Security Incidents

Lost laptops
Stolen devices
Unauthorized access
Password compromise
Phishing attacks
Malware infections
Data leaks
Suspicious emails
Information theft

10.15 Consequences of Violations

Disciplinary action
Suspension
Termination of employment
Legal proceedings
Financial liability
Contract termination
Criminal prosecution

10.16 Our Commitment

Protecting confidential information and intellectual property is essential to maintaining the trust of our customers, suppliers, employees, and business partners.

"Information is an Asset. Trust is Our Responsibility."

11. ENVIRONMENTAL RESPONSIBILITY & SUSTAINABILITY

11.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., we recognize that environmental responsibility is fundamental to sustainable business success. Environmental protection is not only a legal obligation—it is a shared responsibility that guides every decision we make.

ISO 14001 Environmental Management System
Applicable environmental legislation
Customer environmental requirements
International environmental standards
Sustainable development principles

11.2 Environmental Principles

Preventing pollution
Protecting natural resources
Conserving biodiversity
Reducing greenhouse gas emissions
Increasing energy efficiency
Minimizing waste generation
Promoting recycling and reuse
Preventing environmental incidents
Continuously improving environmental performance

11.3 Compliance with Environmental Laws

Air emissions
Water discharge
Hazardous substances
Waste management
Chemical storage
Noise control
Soil protection
Energy consumption
Transportation of hazardous materials

11.4 Pollution Prevention

Prevent spills and leaks
Handle chemicals safely
Maintain equipment properly
Prevent unnecessary emissions
Use approved waste disposal methods
Report environmental hazards immediately

11.5 Climate Change and Carbon Reduction

Improve energy efficiency
Reduce fuel consumption
Optimize transportation routes
Minimize business travel
Utilize digital collaboration technologies
Improve manufacturing efficiency
Support low-carbon engineering solutions

11.6 Energy Management

Switch off unused equipment
Optimize machinery operation
Reduce compressed air losses
Improve lighting efficiency
Monitor energy consumption
Support energy-saving initiatives

11.7 Water Conservation

Prevent unnecessary consumption
Monitor water usage
Repair leaks promptly
Use water efficiently in manufacturing processes
Protect water quality

11.8 Waste Management

Reduce waste generation
Reuse materials whenever possible
Separate recyclable materials
Dispose of hazardous waste safely
Store waste appropriately
Follow local disposal regulations

11.9 Hazardous Materials

Clearly identified
Properly labeled
Safely stored
Handled by trained personnel
Used according to Safety Data Sheets (SDS)
Disposed of through approved methods

11.10 Sustainable Procurement

Environmental performance
Compliance with applicable legislation
Responsible sourcing practices
Resource efficiency
Sustainable manufacturing methods
Environmental certifications where appropriate

11.11 Sustainable Engineering

Reduce energy consumption
Improve operational efficiency
Extend equipment life
Reduce maintenance requirements
Minimize environmental impact
Improve recyclability
Reduce waste

11.12 Biodiversity Protection

Sensitive ecosystems
Protected species
Land restoration
Soil protection
Water resources

11.13 Environmental Awareness

Participate in environmental training
Report environmental concerns
Suggest improvement opportunities
Support recycling initiatives
Promote environmentally responsible behavior

11.14 Environmental Incident Reporting

Oil spills
Chemical leaks
Water contamination
Air pollution incidents
Hazardous waste releases
Environmental permit violations
Significant environmental risks

11.15 Continuous Improvement

Environmental audits
Compliance inspections
Performance indicators
Management reviews
Employee suggestions
Customer feedback
Lessons learned from projects

11.16 ESG Commitment

DEHA TECH supports internationally recognized Environmental, Social, and Governance (ESG) principles.

Environmental:

Climate responsibility
Resource efficiency
Pollution prevention
Sustainable operations

Social:

Employee well-being
Human rights
Diversity and inclusion
Community engagement

Governance:

Ethical business conduct
Transparent management
Legal compliance
Accountability
Risk management

11.17 Sustainable Development Goals

Decent Work and Economic Growth
Industry, Innovation and Infrastructure
Responsible Consumption and Production
Climate Action
Partnerships for Sustainable Development

11.18 Our Commitment

Environmental responsibility is an integral part of DEHA TECH's identity and long-term vision.

"Engineering Sustainable Solutions. Protecting Tomorrow, Today."

12. SUPPLIER & BUSINESS PARTNER CODE OF CONDUCT

12.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., we recognize that our suppliers, subcontractors, consultants, manufacturers, service providers, and other business partners play a critical role in the successful delivery of our projects. Our reputation depends not only on our own conduct but also on the ethical and professional behavior of those who represent or support our business.

12.2 Scope

Suppliers
Manufacturers
Subcontractors
Service Providers
Engineering Consultants
Logistics Companies
Fabrication Workshops
Installation Contractors
Commissioning Contractors
Inspection Agencies
Agents
Representatives
Joint Venture Partners
Temporary Workforce Providers

12.3 Compliance with Laws

National laws
International regulations
Tax legislation
Labour legislation
Environmental regulations
Occupational Health & Safety legislation
Anti-corruption laws
Export control regulations
Trade sanctions
Competition laws

12.4 Business Integrity

Bribery
Corruption
Fraud
Extortion
Embezzlement
Facilitation payments
Money laundering
Bid rigging
False documentation
Unethical commercial practices

12.5 Human Rights

Treat employees with dignity
Prevent discrimination
Respect diversity
Prevent harassment
Respect freedom of association
Provide equal opportunities
Protect employee privacy

12.6 Child Labour

Business Partners shall not employ children below the minimum legal working age. Compliance with ILO Convention No. 138, ILO Convention No. 182, and applicable labour legislation is mandatory.

12.7 Forced Labour

Forced labour
Human trafficking
Modern slavery
Debt bondage
Involuntary prison labour

12.8 Health & Safety

Risk assessments
PPE availability
Safety training
Emergency preparedness
Incident reporting
Machine guarding
Safe lifting operations
Electrical safety
Working-at-height protection
Compliance with customer HSE rules

12.9 Environmental Responsibility

Preventing pollution
Managing waste responsibly
Reducing emissions
Conserving resources
Using chemicals safely
Complying with environmental legislation
Supporting sustainable practices

12.10 Quality Management

Inspection
Testing
Traceability
Document control
Calibration
Non-conformance management
Corrective actions
Continuous improvement

12.11 Confidentiality

Business Partners shall protect all confidential information received from DEHA TECH. NDAs shall be respected at all times.

12.12 Intellectual Property

Business Partners shall respect intellectual property rights. Unauthorized copying, reproduction, or distribution is strictly prohibited.

12.13 Information Security

Customer data
Engineering documentation
Commercial information
Digital systems
Personal information

12.14 Fair Competition

Exchange confidential bidding information
Participate in price fixing
Engage in market allocation
Abuse dominant market positions
Manipulate tenders

12.15 Gifts & Hospitality

Reasonable
Transparent
Infrequent
Lawful
Properly documented

12.16 Conflict of Interest

Family relationships
Financial interests
Undisclosed ownership
Personal benefits
Employment conflicts

12.17 Responsible Procurement

Ethical procurement
Sustainable sourcing
Conflict-free materials
Human rights due diligence
Environmental responsibility
Supplier monitoring

12.18 Audits and Assessments

Conduct supplier assessments
Request compliance documentation
Review management systems
Perform site visits
Verify corrective actions

12.19 Reporting Concerns

Fraud
Corruption
Human rights violations
Safety concerns
Environmental incidents
Data breaches
Conflicts of interest
Serious legal violations

12.20 Non-Compliance

Corrective action requests
Supplier performance reviews
Suspension of new business
Contract termination
Removal from the Approved Vendor List (AVL)
Legal action where appropriate

12.21 Our Commitment

At DEHA TECH, we believe that strong partnerships are built on shared values, mutual respect, and responsible business conduct.

"Strong Partnerships. Shared Values. Sustainable Success."

13. COMPLIANCE, REPORTING CONCERNS & WHISTLEBLOWER PROTECTION

13.1 Our Commitment

At DEHA TECH MAKİNA SANAYİ A.Ş., maintaining an ethical, transparent, and accountable workplace requires every employee to take responsibility for reporting suspected misconduct.

This Code of Conduct
Company Policies
Applicable Laws
Customer Requirements
Contractual Obligations
Ethical Standards

13.2 What Should Be Reported

Employees should report any actual or suspected violation involving:

Business Ethics:

Fraud
Bribery
Corruption
Theft
Conflict of Interest
Procurement Irregularities
Financial Misconduct

Human Rights:

Discrimination
Harassment
Workplace Bullying
Child Labour
Forced Labour
Retaliation

Health, Safety & Environment:

Unsafe Working Conditions
Environmental Incidents
Safety Violations
Failure to Report Accidents
Improper Waste Disposal

Quality:

Falsification of Inspection Records
Non-Conforming Products
Deliberate Quality Deviations
Concealed Defects
Unapproved Design Changes

Information Security:

Data Breaches
Confidential Information Leaks
Cybersecurity Incidents
Unauthorized Access
Intellectual Property Theft

Legal & Regulatory Compliance:

Export Control Violations
Sanctions Violations
Competition Law Violations
Tax Fraud
False Reporting
Money Laundering

13.3 Duty to Report

Every employee has both the right and the responsibility to report suspected misconduct. Ignoring unethical behavior may expose employees, customers, business partners, the Company, and society to unnecessary risks.

13.4 Reporting Channels

Immediate Supervisor
Department Manager
Human Resources Department
Compliance Officer
General Manager
Internal Ethics Committee (where established)

13.5 Confidentiality

All reports will be treated with the highest level of confidentiality. Information will only be shared with individuals who have a legitimate need to know.

13.6 Protection Against Retaliation

Dismissal
Demotion
Salary Reduction
Harassment
Threats
Intimidation
Discrimination
Unfair Performance Evaluations
Exclusion from Projects

13.7 Good Faith Reporting

Employees are expected to report concerns honestly and in good faith. Knowingly making false, malicious, or misleading allegations is unacceptable.

13.8 Investigation Process

Initial assessment of the allegation
Assignment of an investigator or investigation team
Collection of relevant evidence
Interviews with involved parties
Review of documentation and records
Determination of findings
Corrective or disciplinary actions
Documentation and closure of the case

13.9 Cooperation with Investigations

Cooperate fully
Provide truthful information
Preserve relevant documents
Maintain confidentiality
Avoid interfering with the investigation process

13.10 Corrective Actions

Additional training
Policy revisions
Process improvements
Disciplinary measures
Supplier corrective action requests
Contract termination
Notification to competent authorities

13.11 Responsibilities of Managers

Encourage employees to raise concerns
Listen respectfully
Respond promptly
Escalate concerns appropriately
Protect confidentiality
Prevent retaliation
Lead by example

13.12 Compliance Monitoring

Internal audits
External audits
Management reviews
Risk assessments
Compliance training
Performance indicators
Supplier evaluations
Corrective action tracking

13.13 Record Retention

Applicable legal requirements
Company record retention policies
Data protection regulations
Confidentiality obligations

13.14 Consequences of Non-Compliance

Coaching or counseling
Written warnings
Mandatory training
Suspension
Termination of employment
Termination of contracts
Civil legal action
Criminal prosecution

13.15 Our Commitment

DEHA TECH is committed to fostering a workplace where employees feel safe, respected, and empowered to raise concerns without fear.

"Speak Up with Integrity. Act with Courage. Build Trust Together."

14. EMPLOYEE ACKNOWLEDGEMENT & DECLARATION

14.1 Employee Declaration

I acknowledge that I have received, read, and understood the DEHA TECH MAKİNA SANAYİ A.Ş. Code of Conduct.

The DEHA TECH Code of Conduct
Company policies and procedures
Applicable laws and regulations
Customer and contractual requirements
Health, Safety & Environment (HSE) rules
Quality Management System requirements
Information security and confidentiality obligations
Anti-bribery and anti-corruption principles

14.2 Employee Commitments

Act with integrity, honesty, and professionalism
Treat all individuals with dignity, fairness, and respect
Protect confidential information, intellectual property, and Company assets
Follow all applicable health, safety, environmental, and quality requirements
Report suspected misconduct in good faith
Cooperate fully with investigations
Avoid conflicts of interest and disclose them promptly
Support DEHA TECH's culture of ethics and compliance

14.3 Reporting Obligation

I understand that I have a responsibility to report concerns through appropriate channels. DEHA TECH strictly prohibits retaliation against individuals who report in good faith.

14.4 Consequences of Non-Compliance

Failure to comply with this Code may result in disciplinary action, termination, and potential civil or criminal consequences.

Employee Information

14.5 Management Confirmation

14.6 Final Commitment

"I understand that integrity, safety, quality, respect, accountability, innovation, and compliance are the fundamental values of DEHA TECH MAKİNA SANAYİ A.Ş. I commit to upholding these principles in every decision, every action, and every business relationship, while contributing to the Company's reputation for excellence, sustainability, and ethical business conduct."

Document Information

Document Classification: Controlled Document
Confidentiality Level: Confidential
Document Type: Code of Conduct Manual
Revision: Rev. 0
Approval Status: Approved for Internal Use

Document Completion Statement

This document constitutes the official DEHA TECH MAKİNA SANAYİ A.Ş. Code of Conduct and establishes the ethical, legal, compliance, quality, health & safety, environmental, and corporate governance principles applicable throughout the Company.