ANTI BRIBERY AND ANTI CORRUPTION POLICY
Verusa Holding ("Company") and affiliated companies ("Verusa Group") undertake to perform their business activities in an honest and ethical manner on the basis of respect for human rights, and to act in accordance with laws and regulations wherever it operates. For this reason, it is our principle to comply with national laws and international anti-corruption regulations within the scope of our activities.
Our company prohibits making any corrupt payments, offering or undertaking payments to any public official, political party, party officials, candidates or third parties for commercial interests in violation of the Anti-Bribery and Anti-Corruption Policy ("Policy") and the anti-bribery and anti-corruption laws and regulations that we are subject to within the scope of the policy. Within the scope of this policy, Verusa Holding and its affiliated company employees are prohibited from making, offering, undertaking bribes, kickbacks or other illegal and corrupt payments, or brokering or accepting similar payments.
The Policy applies to all employees, partners, agents, suppliers, proxies, mediators, consultants, joint venture partners or anyone acting on behalf of Verusa Holding and its affiliates. Employees of the company and its affiliated companies are obliged to know the anti-bribery and anti-corruption regulations in their places of operation and to carry out activities in accordance with these regulations, understanding that each country has its own regulations regarding payments to public officials and, in many cases, to real persons.
It is forbidden to make donations in kind or in cash to any political party or community in which we operate, under any name, and to allow the use of company assets.
No in-kind or cash payments can be made under any name in order to facilitate and speed up the business of the company and its affiliated companies.
Employees of the company and its affiliated companies cannot give gifts in kind or in cash or make entertainment expenses on behalf of the company or on its account. The Board of Directors may establish a gift and hospitality policy that determines the maximum amount and types of gifts that can be given and hospitality that can be implemented.
Senior management notifies this Policy and changes to those who are covered by it. Senior management is obliged to provide and develop the necessary training on this Policy and applicable anti-bribery and anti-corruption laws and regulations to employees and third parties within the scope of this Policy.
Verusa Group employees will be subject to disciplinary action, including termination of employment, if they violate the Policy or applicable anti-bribery and anti-corruption laws and regulations.
All Verusa Holding and Group Company employees can give feedback at Verusa Holding Ethics Line etikhat@verusa.com.tr or report this situation to the Legal Department in cases of violation of the Policy or considering something as not ethical.
No reprisal is made against personnel who report known or suspected bribery, corruption or suspicious circumstances related to them.
Necessary actions will be taken against personnel who report against the rules of goodwill due to grudge, hatred, competition and similar reasons.
There are reporting systems that will ensure that the identity of the person who notifies non-compliance with the policy is not revealed.
The Legal Department of the Company is responsible for the administration, interpretation and implementation of this Policy under the supervision of the Board of Directors. The Board of Directors undertakes to support the implementation of Ethics Rules, Anti-Bribery and Anti-Corruption Policy.
The Legal Department ensures that an examination is made at least once a year about the effectiveness, implementation and compliance of the Policy with anti-bribery and anti-corruption regulations and informs the Board of Directors.
The Legal Department reviews the Policy, as required or once a year in any case, according to the activities, regulations, developments and changes in risk assessment and submits the necessary changes to the Board of Directors. The Board of Directors evaluates and finalizes the change proposals, if any.