Business Ethics

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Our Ethics Policy

Karaca Packaging's business ethics rules, integrity principles, confidentiality policy and employee responsibilities.

Effective: 2025-07-07 Version 1.0 Türkçe Versiyon

1. Integrity

Honesty and integrity are our priority values in all our business processes and relationships.

We act with honesty and integrity in our relationships with employees and all our stakeholders.

2. Confidentiality

Definition of Confidential Information

Confidential and private information includes:

  • Information that could create competitive disadvantage for Karaca Packaging
  • Trade secrets
  • Financial and other information not yet disclosed to the public
  • Information regarding personnel rights
  • Information within the scope of confidentiality agreements with third parties

Our Confidentiality Commitments

  • We take care to protect the privacy of customers, employees and relevant persons/organisations
  • We use confidential information only for company purposes
  • We share information only with relevant persons within defined authorities
  • Obtaining benefits through leaking confidential information is absolutely unacceptable
  • Confidential information and documents cannot be taken outside when leaving the company

3. Our Responsibilities

In addition to our legal responsibilities, we take care to fulfil the following responsibilities towards our customers, employees, suppliers and business partners, competitors, society and humanity.

  • We conduct all our activities and operations within the framework of Turkish laws and international law
  • We provide accurate, complete and understandable information to regulatory authorities on time
  • We maintain equal distance to public institutions, NGOs and political parties
  • Our financial transactions are carried out in compliance with laws and audited by Certified Public Accountants

B. Responsibilities to Our Customers

  • We work with a customer satisfaction-focused, proactive approach
  • We deliver our services on time and under promised conditions
  • We approach our customers with respect, honour, justice, equality and courtesy
  • We immediately report quality, safety and rule violations to senior management

C. Responsibilities to Our Employees

  • We ensure that employees’ personal rights are used fully and correctly
  • We commit to a non-discriminatory, safe and healthy working environment
  • We make the necessary effort for individual development
  • We observe the balance between work life and private life

D. Responsibilities to Our Partners

  • We prioritise the continuity of the company
  • We avoid unnecessary or unmanageable risks
  • We aim for sustainable profitability
  • We act within the framework of financial discipline and accountability
  • We provide timely, accurate and complete information about financial statements, strategies and investments

E. Responsibilities to Suppliers/Business Partners

  • We act fairly and respectfully
  • We fulfil our obligations on time
  • We carefully protect our business partners’ confidential information

F. Responsibilities to Our Competitors

  • We compete only in legal and ethical areas
  • We avoid unfair competition
  • We support the achievement of the targeted competitive structure in society

G. Responsibilities to Society and Humanity

  • Democracy, human rights and environmental protection are very important to us
  • We support education and charitable works, elimination of crime and corruption
  • We act as pioneers in social issues with the awareness of being a good citizen
  • We are sensitive to the traditions and cultures of Turkey and countries where we conduct international projects
  • We do not give or accept bribes or gifts exceeding their purpose

4. Conflict of Interest

Basic Principles

  • Employees avoid conflicts of interest
  • Personal gain is not obtained by taking advantage of current position
  • No additional financial interest-based business activities outside the company
  • Avoiding using company name and power for personal benefit

Implementation Principles

  • No business relationships providing mutual benefits with family members or friends
  • Commercial benefit cannot be obtained by leaking company information
  • Duties in non-profit organisations can be undertaken with written approval from management
  • Participation in political activities is subject to written approval from management
  • Political activities cannot be conducted during working hours

5. Abuse of Position

  • Using authority for personal and/or relatives’ benefit is unacceptable
  • Personal gain cannot be obtained from purchasing and sales activities
  • Acts and behaviours contrary to morality, law and company discipline are prohibited

6. Use of Resources

  • Company resources are used considering company interests
  • “Economy in everything” principle is applied by all personnel
  • No time is allocated to personal matters during work hours
  • Managers cannot assign employees to personal tasks
  • Private visitors are not accepted during working hours as a rule

7. Rules in Commercial Relations

Prohibited Behaviours

  • No private business relationships with customers, subcontractors or suppliers
  • No borrowing of money and/or goods/services for personal purposes
  • No transactions without customer knowledge
  • No taking advantage of customer weaknesses

Gift Policy

  • Gifts cannot be requested or implied
  • Gifts, money, cheques, property, free holidays, special discounts that impose obligations on companies cannot be accepted
  • Gift Acceptance and Giving Policy applies

8. Company Representation

Representation Rules

  • Fees accruing from duties in associations, unions etc. are donated
  • Seminar speaker fees etc. payments are donated to relevant institutions
  • Awards, shields etc. with symbolic value other than money can be accepted

Implementation Principles

  • Gifts or benefits that may affect impartiality, decisions and behaviours are not accepted
  • Gifts compatible with institutional business objectives and compliant with regulations can be given/received
  • Gifts explicitly or implicitly tied to reciprocity are prohibited
  • Bribery and/or commission giving, taking or offering is unacceptable under any circumstances
  • Unconditional money acceptance from sub-employers, suppliers or customers is prohibited

9. Confidential Information Protection Policy

Scope of Confidential Information

Confidential Information includes:

  • Intellectual property rights such as trademarks
  • Databases, printed communication materials, processes
  • Marketing, product and technical plans
  • Business strategies and partner information
  • Financial information and personnel information
  • Customer lists and product designs
  • Know-how and specifications

Protection Rules

  • Confidential information cannot be disclosed to third parties unless required by Official Authorities and Legislation
  • Information cannot be altered, copied or destroyed
  • Confidential files cannot be taken outside the institution
  • Passwords and user codes are kept confidential
  • Confidential information is not discussed in public places
  • Confidentiality agreements are signed when sharing information with third parties
  • Personnel salary and personal information is confidential

10. Creating a Fair Working Environment

Basic Principles

Karaca Packaging considers the creation and maintenance of a fair working environment for employees as one of its most important priorities.

Implementation Principles

  • Company practices comply with all applicable laws and regulations
  • Recruitment, promotion, remuneration and reward practices are fair
  • No discrimination based on language, race, colour, gender, political opinion, belief, religion, age, physical disability
  • A collaborative and positive working environment is created
  • Private life and personal space of employees are respected
  • Personal data cannot be given to others unlawfully
  • Employees’ physical, sexual and emotional integrity is protected
  • Sexual harassment is strictly prohibited and not tolerated
  • Workplace physical working environment must be healthy and safe for all employees

Managers’ Responsibilities

Managers have the following additional responsibilities:

  • Creating a company culture that supports ethical rules
  • Being an example with their behaviour in implementing ethical rules
  • Training employees on ethical rules
  • Supporting employees in communicating questions, complaints and reports
  • Taking reports into consideration and forwarding to Ethics Committee when necessary
  • Structuring business processes to minimise ethical risks

Other Responsibilities

Senior management is responsible for effective implementation of Business Ethics Rules.

Human Resources Responsibilities

  • Informing employees about rules and providing training
  • Ensuring new employees read ethical rules and sign documents
  • Guaranteeing confidentiality of complaints and reports
  • Ensuring job security of employees who report
  • Investigating complaints and reports fairly and consistently
  • Ensuring employees receive training at least once a year
  • Evaluating risks and ensuring revision of policies

Resolution of Non-Compliance with Ethical Rules

Those who violate Business Ethics Rules or company policies will be subject to various disciplinary sanctions, which may even result in termination of employment.

Disciplinary sanctions will also apply to those who approve, direct inappropriate behaviours or who are aware but fail to make the necessary report.

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