As a leading company operating in the Turkish automotive supply industry, Nursan exports its products to various countries. The Company aspires to be a preferred business partner in the automotive industry for its quality, price, lead time and R&D capabilities and strives to respect its employees and society in all its activities.

The objective of this Policy is to define the shared values, principles, and the continuous improvement approach that the Company employees are expected to adopt while performing their duties. We respect the privacy, personal rights, and dignity of all our employees, and expect them to do the same for others. We do not tolerate any discriminatory behavior based on gender, age, political view, race, nationality, ethnicity, and religious belief. Furthermore, we do not allow or tolerate any harassment, threat, violence, or intimidation. The employees are strictly prohibited from abusing their position and authority within the Company, engaging in corruption, fraud, or bribery, and disclosing the Company’s Confidential Information or Trade Secrets.

Our employees, customers, suppliers, subcontractors, and business partners are required to comply with our Code of Conduct, Code of Ethics, Anti-bribery and Anti-corruption Policy, and Zero Tolerance Policy. Nursan Kablo Donanımları Tic. ve San. A.Ş. reserves the right to terminate the business relationship with individuals and organizations that do not comply with these policies.

Our employees are required to comply with applicable laws and regulations, Code of Conduct, Code of Ethics, Anti-bribery and Anti-corruption Policy, and Zero Tolerance Policy. Furthermore, we expect our employees to report any violations of these policies and codes to the Ethics Committee by sending an email to etikkurul@nursankd.com.

NURSAN KABLO DONANIMLARI SAN. VE TİC. A.Ş. declares and warrants that it will not tolerate the following issues within its organization and that it stands against such practices.

The principles outlined below reflect the values we promote in this policy.

1. GENERAL PRINCIPLES

Nursan follows the general principles described below in all its operations. All Nursan employees are required to adhere to these general principles in their relations with customers, suppliers, shareholders, and all other stakeholders.

1.1 Integrity

Nursan acts with honesty and integrity in all its operations and relations with its employees, customers, suppliers, shareholders, and all other stakeholders.

1.2 Transparency

Nursan ensures transparency and openness in its relations with its employees, customers, suppliers, shareholders, and all other stakeholders. Accordingly, Nursan provides clear and accurate, complete and timely information in all its operations.

1.3 Inclusivity

Nursan does not tolerate discrimination against its employees, customers, suppliers, shareholders, and other stakeholders on the basis of religious belief, language, race, gender, health condition, marital status, or political view, etc. At Nursan, all people are treated fairly and equally, without any bias.

1.4 Confidentiality

All information regarding the company, including but not limited to trade secrets, intellectual property rights, financial and other information, information in the personnel files, and NDA agreements with third parties are considered confidential information.

Nursan exercises due diligence to protect the personal information of its employees, customers, suppliers, and other stakeholders, and does not allow such confidential information to be disclosed to third parties. Confidential information can only be used by authorized persons within the company according to ethical rules and only in the interest of the Company. All employees declare their agreement to protecting confidential information by signing a document.

1.5 Compliance with laws and regulations

Nursan Kablo Donanımları San.ve Tic. A.Ş. follows the laws and regulations in all its operations and takes necessary measures to ensure compliance.

1.6 Decent Work, Advertising, Competition

Nursan follows the laws and regulations on decent work, advertising, and competition in all the countries where it operates. Furthermore, Nursan does not compromise the principles of honesty and integrity in competition.

1.7 Protection of Intellectual Property

Nursan protects intellectual property rights and strives to prevents damage to intellectual property rights by ensuring legitimate use and avoiding misuse of intellectual property rights.

1.8 Anti-corruption and Anti-bribery (Conflicts of interest)

In all the activities and operations across the organization, Nursan considers the business interests and avoids conflicts of interest. Accordingly, all Nursan employees are required to adhere to this principle. Nursan does not allow or tolerate any form of bribery and corruption. Therefore, Nursan adopts a zero tolerance approach and is highly sensitive to bribery and corruption. Nursan will not allow personal interests to affect the employees’ ability to care for company interests, which is our top priority. Furthermore, Nursan will not tolerate abuse of power, authority, or Nursan identity to create benefits for personal interests or close relatives and friends. In addition to ensuring compliance with anti-corruption laws, Nursan adheres to the highest standards of integrity in all its business dealings. Nursan does not allow its employees to accept or request gifts or other benefits, business dinners, or other entertainment expenses from its customers and suppliers. However, if rejecting a customer’s or supplier’s gifts would be perceived as discourtesy to the gift giver, it may be accepted on condition that its value does not exceed TL 500 or equivalent in foreign currency. Such a gift would be randomly assigned to an employee or made available to all if it is a gift that can be used by all employees. Nursan applies zero tolerance to bribery and corruption, fraud, extortion, embezzlement, money laundering, bid rigging, gaining improper benefits, and unethical behaviors.

1.9 Anonymity and Prohibiting Retaliation

Nursan protects the individuals reporting violations of ethical rules against retaliations and keeps their identities anonymous as an extra security measure.

1.1 Freedom of Employment

Nursan prohibits all forms of forced labor, including debt-based work, slavery or human trafficking, and physical abuse. The Company complies with all applicable local and national laws regarding forced labor and employee abuse. The employees are not required to pay any recruitment fees and other charges for their employment. Their identifications are only retained for the reasonable time required for administrative procedures, and their freedom of movement is not restricted. Nursan expects all its suppliers to protect and respect human rights in accordance with international conventions. Nursan will not allow or tolerate violence, harassment, or inhumane treatment.

1.2 Youth Employment and Internships

We do not employ or promote child labor. We comply with all applicable laws and regulations on youth employment and internships. We also ensure occupational health and safety by not allowing night shifts or overtime in a manner that may endanger their health and safety.