The objective of this policy is to specify the commitments that should be made by employees of Bati Nakliyat ve Ticaret A.S. (BATI) during the performance of their duties and while acting based on the mission of representing BATI, and to define the ethical values integrated into the company's fundamental values and indicators of compliant behaviour. The Policy applies to employees working in all business places of BATI.

Company employees are obliged to comply with ethical values during the performance of their duties. Our business ethics rules, which are based on our company values, have been established with the awareness that business procedures, instructions, laws and regulations may not guide our attitudes and behaviours. Situations and behaviours not specified in this procedure should be interpreted based on and in parallel with this mindset, and appropriate ethical behaviours should be displayed.


2.1. Compliance with the Laws

The Company's management and employees act in compliance with the applicable legal requirements in all activities. It is strictly forbidden for our employees to falsify the official documents issued during the performance of their duties.

2.2. Integrity

Integrity and honesty are among our primary values in all our business, operation, processes and relationships. We are based on honesty and honesty in our relations with the government, our customers, our employees and all other stakeholders, and we act with the importance and priority of creating a reliable image.

2.3. Respect to the Environment

The position of our companies and employees is not to harm the environment with our activities, protect the environment and show responsibility about the environmental problems. We support environmentally friendly activities and collaborations in line with our capabilities.

2.4. Discrimination and Marginalization

Our Company respects the equality of opportunity. Our prospective employees and employees are not exposed to any discrimination, marginalization or harassment due to gender, country, nationality, sect, age, race, color, religion, language, sexual preferences or disability.

2.5. Proper Use of Company Resources

Proper, regular and correct use of all kinds of company resources such as people, money, buildings, tools, equipment, time, etc. is essential and misuse of these resources is not tolerated. Our employees must carefully protect the company assets we have and use them efficiently. Company interests are taken into account in all uses of resources. Company assets and facilities may not be used for personal purposes.

Time is an important asset for the company and it is essential to use it efficiently and productively during working hours. Employees should not spare time for their personal business during business hours, and should use their time to fulfill their duties and responsibilities. It is essential that no private visitors are accepted during working hours. In obligatory cases, the meetings should be completed in a reasonable time in connection with the subject of the visit and in a way that does not hinder the workflow. Managers are not entitled to assign employees for their personal business.

2.6. Relations with the Press and Media

The spokesperson determined by the senior management is authorized to make written or verbal statements about the company and activities thereof. Financial and all sensitive information is transmitted only through the spokesperson. Making a statement to any press / broadcasting organization, giving an interview, seminar-conference, etc., participation as a speaker is subject to the prior written approval of the BATI Board of Directors. No personal interest may be obtained as a result of these activities. In the channels accessible on the Internet, in the social media, in the press and media and in all other public channels, actions are taken in accordance with the following rules:

· Company's tradename and information must be written correctly.

· Information that is not related to facts should not be given.

· Inaccurate, misleading, baseless, defamatory, damaging, etc. information or comments may not be given about our company, customers, suppliers and competitors, and it is not permitted to engage in any discussions with any third real or legal person.

2.7. Confidentiality and Protection of Trade Secrets

During the performance of their duties, our employees may not disclose confidential information or trade secrets they have learned about the company or third parties with whom they have business relations, in any medium or by any reason whatsoever. They pay high level of care and attention to the confidentiality of such information.

The employee is obliged to act in accordance with the matters specified within the scope of the employment contract and confidentiality agreements executed with third parties. It is essential that such confidential information is used only for corporate purposes and only shared with relevant persons subject to the authorizations made. It is strictly forbidden to use this information for obtaining any commercial interest.

Employees are not permitted to take the confidential information and documents, and works such as projects, regulations, etc. that are in their possession by reason of their duty, out of the company while leaving the company.

Employees must ensure that confidential documents that need to be destroyed are destroyed so that they cannot be accessed again.

Subjects containing information that may harm the company or its customers are not discussed in the areas where customers or other third parties are present.

Company information (procedure, instructions, forms, etc. all documents) and internal correspondence may not be shared with outsiders, taken out of the company or transferred electronically. In case of any potential situation that may require providing the information described above, the opinion of the senior management is taken and actions are taken accordingly.

2.8. Competition

Our companies and employees are sensitive about behaving ethically, in compliance with the law and in integrity while competing with our competitors. In this regard, they do not behave in a way that will put our company in a difficult situation and damage its image.

2.9. Avoiding Conflict of Interest, Gifts

A conflict of interest is a situation that indicates the potential of a real or legal person to obtain personal or corporate interests by improperly using the status, purpose and mission of that real or legal person.

As BATI, we display behaviours that avoid situations that may create a conflict of interest in our activities. All of our employees are expected to adhere to high standards of business ethics/ethics based on fairness, objectivity and professionalism, and avoid conflicts of interest when doing business with third parties on behalf of the company. It is unacceptable for company employees to exploit their positions to obtain personal interests or interests for others.

Batı employees will not accept or attempt to give gifts and interests that may affect their impartiality and decisions in their relations with third real or legal persons. Products such as calendarts, pens, etc. which have symbolic/ reasonable monetary value are exceptions.

It is forbidden for a Batı employee and his family or relatives to obtain personal interests by taking advantage of the employee's position in the company, and to have relations with individuals or organizations that may benefit from the confidential information in their possession. Our employees should pay utmost care for protecting the interests of the company and avoid acts and behaviours that may serve to their own interests or interests of their relatives while doing their jobs.

In the event that an employee wants to do business with our company by establishing a company or as a partner/employee of another company after leaving his/her job in the company, our current employee who will be in contact with him/her should pay utmost care to the interests of our company before or after the business relation and behave in a way that does not allow any potential conflicts of interest. In such a case, the approval of the General Manager must be obtained before establishing any business relationship.

The Company may be represented in the events such as trainings, celebrations, conferences, introductions that are open to public and organized by real or legal persons such as customers, suppliers, etc. that have or may have the potential to be in a business relationship with our company. Accepting an invitation (sports, cultural or social) that may be effective in decision-making processes or that can be perceived as such, is possible provided that they are directly related to the business and that the customer or supplier makes that invitation to other stakeholders in the ordinary course of business. In case of invitations, reasonable actions are taken without exaggeration.

2.10. Anti-Bribery - Anti-Corruption- Anti-Money Laundering

Our company has a policy that prohibits its employees from offering, giving, accepting or receiving bribes. Corruption is strictly forbidden. Our employees give/ receive gifts to / from only the persons, organizations and institutions in business relationship with our Company, solely subject to the limitations set for this purpose. Money laundering is an act of concealing the source of a proceeds of crime, which constitutes a very serious offense for the official authorities and causes other crimes to be committed. The company or employees thereof are strictly prohibited from participating in or facilitating any such transaction.

2.11. Impartiality

Our company is equidistant from any existing or future political parties and activities. The Company avoids helping any of them and does not take part in political activities. During the performance of operations, the Company complies with its obligations with the awareness of its responsibilities and without any expectation from any public organization and institution, administrative body, non-governmental organization and political party.

2.12. Harassment and Malfeasance

Harassment may be defined as exposing a person to humiliating, distressing and defamatory behaviours in a consistent and wearisome manner. Our Company is strictly against any form of physical, sexual and psychological harassment and malfeasance in every field of business and business operation. Employees are treated with respect and courtesy and behaviours that create an ill-intentioned and violent working environment are not allowed and persons with tendency to show this type of behaviours are not tolerated.

2.13. Our Position Towards Customers, Employees and Suppliers/ Business Partners

BATI has a position based on the awareness of its responsibilities towards the parties in the business ecosystem and conducts its operations in parallel with this position.

a. Our Position Towards Customers

  • We work with an understanding that will create customer satisfaction and always increase the satisfaction with the service quality we provide.
  • We take a proactive approach to respond to our customers' demands as soon as possible and in the most accurate way.
  • We conduct our communication activities within the framework of the correct style, respect and courtesy rules.
  • We protect confidential information with utmost responsibility.

b. Our Position Towards Employees

  • We do not employ individuals below the age of 18.
  • We do not discriminate our employees based on gender, country, nationality, sect, age, race, color, religion, language, sexual preferences or disability. In our recruitment process, we decide according to the requirements of the job.
  • We respect and protect the legal rights and fundamental human rights of our employees.
  • We take the necessary precautions regarding Occupational Health and Safety and create a safe and healthy working environment.
  • We act in accordance with official working hours.
  • We carefully store the personal information of our employees in accordance with KVKK and act accordingly.
  • We pay our employees in line with the laws and industry practices. We attach importance to wage confidentiality and expect the same from our employees.
  • We support our employees in their career development, offer opportunities and encourage them to take these opportunities.
  • We support a communication environment where our employees can easily express their thoughts, opinions and proposals.
  • We offer equal opportunities to all our employees, starting from the recruitment process.
  • We attach importance to the development of our employees and invest in their future within the framework of requirements and a system.
  • We respect private life and work-life balance of our employees.
  • We do not allow our employees to display aggressive attitudes and behaviours that damage the efficiency and integrity of the working environment, disturb other employees, engage in emotional and sexual harassment, and promote commercial, political and religious purposes.
  • We prevent all kinds of harassment, abuse and intimidation against our employees, we do not allow them.
  • When necessary, we implement our disciplinary procedure and act according to the rules stipulated in the laws.
  • We know that no one can be forced to work, we create a working relationship on a voluntary basis. Our employees are free to decide to leave in accordance with legal requirements.

c. Our Position Towards Suppliers/ Business Partners

  • We treat our suppliers/ business partners equally and with respect.
  • We show diligence to comply with the mutually agreed obligations in timely manner.
  • We protect confidential information with utmost responsibility.



3.1. Notification

Our employees, customers, suppliers and business partners may serve a notification in writing or verbally on their findings and suspects about the matters detailed in this procedure and through the communication channels specified below, within 5 working days, without revealing their identity, if they wish to do so. All notifications will be treated confidentially.

Communication channels for notifications to the Ethics Board:

E-mail :

Phone : +90 212 293 24 00 - Ext. 106

Address : Büyükdere Cad. Akabe Ticaret Merkezi No: 78-80 Fl: 2/202 Gayrettepe 34394 İstanbul, Turkey

3.2. Subject of Notifications Made Over Ethical Channels

Primary subjects are listed below for the notifications of employees or 3rd persons (customers, suppliers, etc.) that may be served about harassment over ethical channels.

  • Executives or non-executive employees committing, encouraging or allowing discrimination of employees based on gender, nationality, origin, religious sect, age, race, colour, religion, language, sexual preferences or disability.
  • Exposure of employees to psychological, physical or sexual abuse, humiliating or defamatory behaviours on consistent and systematic manner, encouraging or allowing this type of behaviours.
  • Establishing secret or open commercial partnerships with customers, suppliers or business partners, engaging in activities that require them to be considered merchants and tradesmen.
  • Providing benefits to customers, suppliers or business partners, accepting gifts directly or indirectly, giving gifts for personal interests.
  • Abuse or use of power or authority for private interests.
  • The embezzlement of money, property or other assets.
  • Falsification, procurement of falsification of all kinds of books, documents, invoices and records and destruction or encouragement of the destruction of the same in bad faith.
  • Theft, fraud, forgery or other infamous crime.
  • Payment of personal expenses with company resources.
  • Revealing company's or customers' secrets and/or obtaining interests by accessing these secrets.
  • Damage to the company through abuse of power.
  • Taking the information of the company out of the company in bad faith or mediating or attempting to take it out of the company.
  • Making unregistered use of the cash in the company's safe to employees or third parties.
  • Damaging the image, reputation and credibility of the company by doing wrong works and transactions on an unlawful and deliberate manner.

Notifications shall be made solely for the matters described in Article and for which examples are provided above, and any claim such as complaint, proposal, objection etc. that contain dissatisfaction shall not be processed.

3.3. Evaluation of Notification

Notifications made inside or outside the company are evaluated by our company's Ethics Committee. The consistency of the subject and the importance of the information are evaluated, a detailed examination and investigation is carried out, and the final decision is made on taking the necessary measures and actions. Based on the decision to be made, if deemed necessary, action will be taken against the relevant persons in accordance with the Disciplinary Procedure.

All notifications are recorded and carefully evaluated. The Ethics Committee may request information and data from any department upon the need for investigation. It regularly reports its results to the General Manager and the Board of Directors. The Ethics Committee has the authority and responsibility to monitor the results, the measures taken by the senior management and management units and the actions taken.

3.4. Ethics Committee

The Ethics Committee is responsible for investigating and solving the complaints and notifications on violation of ethics in accordance with the Ethics Policy and it reports to the Board of Directors.

The Ethics Committee consists of the individuals in the following positions:

Chairperson - Human Resources and Quality Systems Director

Member - Financial Affairs Director

Member - Internal Audit and Risk Management Director

Operating Principles of the Ethics Committee:

  • Notifications received and identity of notifying persons are kept confidential.
  • Investigation is conducted in confidentiality to the extent possible.
  • It is authorized to demand the information, documents and evidence related with the investigation and evaluation directly from the relevant departments. The relevant departments are obliged to provide the required information and documents.
  • Investigation process is documented in writing starting from the beginning. Information, documents and evidence are enclosed to the report.
  • In performance of their duties, chairperson and members of the Committee act in a manner independent and impartial from the hierarchy within the organization and their immediate managers. They are not exposed to any pressure and persuasive efforts.
  • The Committee may obtain expert opinion and use experts by taking measures in parallel with the confidentiality principles during the investigation as and when deemed necessary.
  • Activities are carried out expediently during the processing of notifications.
  • Decisions of the committee are implemented immediately and the relevant internal and legal proceedings are initiated.
  • If known, the notifying party, the relevant departments and managers thereof are informed about the outcome.
  • Disciplinary process is initiated against the employees who make retaliation against the employee who notifies the Ethics Committee.