Code of Ethics

• We are committed to meeting or exceeding all applicable laws, rules and regulations in force in the countries in which we are active.
• We comply with the regulations, instructions, procedures and job definitions of our Company.
• We take full responsibility of the results of business we do and manage.
• We keep and archive all printed and electronic records within the scope of our responsibilities and powers accurately, truthfully, on time, and in accordance with the law.
• We do not provide any inaccurate information, and we support our actions with accurate information and documents
• We ensure the reliable and effective operation of the internal audit system.
• Provided that they are not regulated by law, we protect shareholder rights within the framework of business ethics without sacrificing the interest and reputation of our company,
• If we are aware of or suspect a breach of this Code we promptly report it to the Ethics Committee, even if our own manager is involved in it.

• We take responsibility for the authority we use and show accountability for our actions.
• We do not use the name or the power of our company to gain personal benefits.
• We do not use any corporate resources including but not limited to intellectual or industrial assets, goods, equipment, vehicles, tools, and computer hardware and software for our own or someone else’s benefit.
• We do not seek personal interest in any purchasing or sales operation we undertake on behalf of our company.
• We do not seek benefits for ourselves, family, or friends from persons and companies with whom we have established a business relationship.
• We do not establish supplier and/or customer relations with our family members. In the event of exceptions, we take permission from our manager and immediately notify the Business Ethics Committee.
• We notify the Business Ethics Committee of any first-degree relatives working in our company, customers, suppliers, or competitors.
• We do not communicate with our family or friends in competing companies in breach of the principles of competition and we do not disclose any private corporate information.
• We do not accept any gifts, accommodation, or benefit in any other manner that is worth above 1000 Turkish liras that may impact our impartiality, decisions, and attitude. We do not accept cash or equivalent in any amount under any circumstances.
• We do not gift the companies or persons with whom we have established a business relationship, except for flower bouquets and corporate gifts delivered to our business partners on special occasions or for advertising.
• We do not borrow from or lend to people with whom we have established a business relationship.
• We do not accept or offer bribes directly or indirectly under any circumstances.
• Whatever the cause may be, we do not work for any other persons and/or company in exchange for money or any other benefits within or outside of work hours. In the event of exceptions, we can obtain permission from the top manager of the relevant business department.
• When we receive an invitation to represent the company at an event (seminar, training, sports game/concert organization), we first obtain permission to participate from the top manager of our department.
• We are careful to establish that our personal opinions do not reflect those of the company.
• We obtain permission from the top department manager before making a press statement, giving an interview, or speaking at a seminar or conference. We do not seek personal gains from such activities.
• We do not use corporate letterhead papers or email accounts to express our personal opinions or for personal business, and we do not speak or write on behalf of the company unless specifically authorized.

• We prevent the loss, damage, misuse, waste, or transfer of corporate assets, as well as their sales and donation unless permission has been obtained from the upper management.
• We register for the company any intellectual or industrial inventions and innovations created during corporate operations. We ensure that all intellectual property rights stemming from services obtained from third parties are transferred to our company.
• We do not allocate work hours for our personal business with the exception of necessities.
• If we are using communication devices such as email, telephone, and internet for personal reasons, we do so in a brief and temporary manner and ensure that this usage does not conflict with our business responsibilities.
• We keep the user names and passwords assigned to us safe and secret. We do not tolerate others logging on to the system using our personal user password.
• We avoid the inappropriate use of computer systems, corporate email accounts, and the internet. We keep in mind the below principles when using these resources, and we avoid uploading, copying, or electronically disseminating this content.
• We do not send emails that are discriminatory towards gender, age, race, ethnicity, religion, or political views, or that are in any way threatening, insulting, disparaging, slandering, or humiliating.
• We do not enter websites that contain sexually explicit content, facilitate gambling, or advocate for illegal activities.
• We do not use copyrighted articles, artwork, movies, photographs, music, presentations, data, software, and similar materials that would constitute a breach of the law.
• We avoid sending chain letters or “spam.”
• We do not share content that may damage our company or our products, that represents the personal opinions of a user in our company, that supports any commercial companies or initiatives, or that slanders or disparages any other company’s reputation, products, or services.
• We do not share information or comment relating to our company on chat rooms, bulletin boards, blogs, newsgroups, or any other similar medium without the permission of the top manager of our department.
• We do not share any private corporate information that we may have gained insight into through our duties with our colleagues, families, or any other third parties outside of the Sütaş Group.
• When working on or speaking of our company in public places, we are careful to prevent the sharing or release of any private corporate information.
• If we are leaving the company, we must relinquish all print or electronic documents, including copies thereof, belonging to the company to our manager. We do not make any statements that will damage our corporate reputation.

• We personally contribute to establishing and maintaining a friendly working environment and a culture of mutual respect.
• We believe that success is a team game. We work in cooperation and solidarity.
• We refrain from aggressive attitudes or threatening approaches that negatively impact workplace efficiency and order and influence our colleagues’ motivation.
• We comply with all procedures, rules, and instructions concerning the occupational health and safety of our colleagues and/or team. We do not risk ourselves or others with our actions.
• When in the workplace, we are responsible for ensuring that our behavior and that of our colleagues comply with the Code of Ethics.
• We do not use alcohol or illicit drugs in the workplace. We do not smoke outside of the designated areas.
• We respect the personal lives and personal spaces of our colleagues.
• We protect the personal information of our colleagues.
• We refrain from taking actions that will damage the reputation of our colleagues. We do not verbally, physically, sexually, and/or emotionally abuse anyone.
• We do not disclose our wage, extra revenues, or real rights with our colleagues. We do not attempt to find out such information about others.

Our Consumers

• We undertake personal responsibility in achieving Sütaş’s mission and promise of delivering “Tasty and Natural Food.”
• We act as a Sütaş brand ambassador in our personal relations and defend the rights of our company.
• We do not derogate our competitors when discussing with consumers.
• We inform our consumers thoroughly and accurately. We direct them to the Sütaş Hotline when we lack sufficient information.
• We obtain permission from our consumers for all interviews, research, and communication (including mobile and internet).

Our Suppliers and Customers

• We establish relations based on honesty, fairness, and respect with our suppliers.
• We choose our suppliers in a fair, systematic, and professional manner.
• We fulfill our responsibilities toward our suppliers and customers in a timely manner.
• We refrain from any actions that might lead to unfair competition for our suppliers and customers.
• We do not disclose the terms of agreements between our company and suppliers.
• We do not launch a business with our suppliers or customers without written approval for a quote, a protocol, or an agreement.
• If we are to disclose any private information pertaining to our company, we first sign a confidentiality agreement with our suppliers or customers.
• We protect the private information of our suppliers and customers.
• We refrain from statements that may damage the reputation of our company or our colleagues in our communication with suppliers or customers.

Public Institutions and Civil Society Organizations

• When contacting any public institutions, civil society organizations, or political parties as part of our job, we keep our personal opinions out of our business relations and remain at an impartial distance from such institutions.
• We refer to our top department manager to learn about the laws, regulations, or rules to abide by in our relations with the public institutions.
• In case of interrogation or investigation, we provide accurate information to official authorities.

Competitors

• We learn about the laws and regulations on competition and manage our relations within that scope.
• If we are to contact competitors as part of our job, we first inform our department manager of such communication.
• We do not share any disparaging publications and statements concerning our competitors on any platform, including social media.
• We refrain from actions and attitudes that might lead to unfair competition.