Anti-Corruption Policy

The policy of Tüpraş is to comply with all applicable laws and regulations, to act in an ethically responsible manner consistent with its values and Code of Ethics, and to put policies and procedures in place to ensure integrity in conducting business. Tüpraş also expects that any outside person or company acting on behalf of Tüpraş conducts its business lawfully, ethically, and in compliance with Tüpraş’ values and standards. Tüpraş has prepared its Anti-Corruption Policy and Trade Control Policy (together” the Policies”) to set out in additional detail the most important elements of the company’s program for preventing corrupt conduct and to comply with export control laws respectively. Tüpraş is intending to bring into effect and roll-out its Policies shortly. It is the shared responsibility of all personnel to understand Tüpraş’s Policies and ensure that the company’s procedures are upheld. A brief summary of the scope and purpose of of each of these Policies are as follows:

Purpose of this Policy is to ensure compliance by Tüpraş with the provisions of anti-corruption laws, rules and principles including the Turkish Public Officials Act, the Criminal Code, the Code of Misdemeanors, the US Foreign Corrupt Practices Act, the UK Bribery Act, and the OECD Convention on Combatting Bribery. Compliance with Tüpraş’ Anti Corruption Policy by allpersonnel is mandatory at all times. Any employee, officer, manager, coordinator, and director of Tüpraş is required to read, understand and comply with this Policy. Tüpraş also expects that any third party conducting business on behalf of Tüpraş, its customers, suppliers and other business partners commit themselves to comply with this Policy while doing business with or on behalf of Tüpraş.

Within the context of the Policy, our personnel and business partners doing business on behalf of Tüpraş will be required to sign a certification of compliance. In addition, appropriate amount of due diligence will be conducted, especially for the Third Parties and also for the companies that we do business with. Furthermore, compliance terms and conditions will be included in the agreements that we sign with the third parties.

In conjunction with this Policy, updated and improved version of our Code of Ethics has also been prepared and will be rolled out simultaneously.

Purpose of the Export Control Policy is to ensure that none of our existing nor potential business partners are included in any international Restricted Party Lists. This Policy provides information on the consequences of transacting with any Restricted Party or sanctioned country maintained by US, EU and UN and sets out the most important elements of the company’s program to prevent improper conduct.

As per the Policy, Tüpraş personnel are required to obtain relevant information about the persons and entities with which they do business. All customers, vendors, and other business partners are required to complete the relevant Tüpraş pre-qualification questionnaire and provide detailed information including their shareholder structures and ultimate beneficial owners to enable Tüpraş to conduct an appropriate level of due diligence. All parties involved in a transaction including vessels, brokers, and financial institutions should be screened properly.

This Policy will be provided to active business partners and required to sign a Deed of Undertaking stating that the business partner will comply with this Policy. Also, Tüpraş will ensure to include relevant compliance terms and conditions in its agreements with the third parties.

  • Any suspicious cases referred to the Compliance Officer. We have already started training Tüpraş employees on both of the Policies and relevant regulations. Supplementary and updating training will be available for the key employees who are responsible for day-to-day compliance with this Policy by virtue of their work assignments.

  • Sufficient channels have been provided for our employees to report any suspicious case to the Compliance Officer.

  • We have started to inform our employees about the consequences of any violation of the Policy. It has been clearly stated that compliance is mandatory, and any individual that fails to comply or report any suspicious case will be subject to appropriate disciplinary action, including termination.