Anti-Bribery and Anti-Corruption Policy


1. Purpose

The purpose of Anti-Bribery and Anti-Corruption Policy (the Policy) is to disclose Anti-Bribery and Anti-Corruption policies of Palmet Group (PALMET) is to ensure compliance of employees.

2. Scope

Anti-bribery and anti-corruption policy covers:

  • All PALMET employees including the Board of Directors,
  • Companies from which we outsource good and services and their employees, people and agencies working on behalf of PALMET including consultants, lawyers, external auditors

3. Definitions

Corruption is the misuse of the authority held due to the position for the purpose of gaining advantage directly or indirectly.

Bribery is a person's gaining advantage or providing advantages to others within the framework of an agreement reached with a third person so that such person acts in breach of the requirements of his/her duty by doing or not doing a work, speeding up or slowing down thereof, etc.

Bribery and corruption may occur in various different ways, among these:

  • Cash payments,
  • Political or other donations,
  • Commission,
  • Social benefits,
  • Gift, hosting,
  • Other benefits

can be mentioned.

4. Duties and Responsibilities

Implementation and updating of the Anti-Bribery and Anti-Corruption Policy are in the responsibility and duties of the Board of Directors. In this context, the followings are required:

  • The Board of Directors shall establish an ethical, reliable, legal and controlled working environment,
  • Senior management is required to evaluate risks and establish the necessary control mechanisms in compliance with the principles of Board of Directors,
  • Board of Directors are required to evaluate whether operations are carried out safely and in compliance with legal regulations within the scope of their duties and it is monitored by systematic and various reporting conducted by Internal Audit and Risk Department, Financial Affairs Department and/or Legal Department.
  • In case policies, rules and regulations are not complied with, report, review and sanction mechanisms must be determined and operated.

Moreover, all PALMET employees are responsible for;

  • ensuring compliance with established policies of the Board of Directors.
  • effectively managing the risks associated with their business operations.
  • working in a manner consistent with the relevant legal regulations and the applications of Palmet
  • informing the Ethic Rule Advisor or Board of Directors if they encounter with a conduct, activity or application which are in breach of the Policy

5. The Companies from/to Which Good and Services are Bought and Sold and Business Partners

The companies from which goods and services are bought and to whom goods and services are sold and Business Partners must comply with the Policy principles and other relevant regulations. Relations with persons and institutions failing to comply these conditions shall be terminated.

5.1 Selection of Companies and Business Partners

In addition to criteria such as experience, financial performance and technical sufficiency, Senior Management takes into account morality and a positive background in this field during the selection of the companies from which goods and services are bought and to whom goods and services are sold and the Business Partners. The companies and the Business Partners which have a negative information with regard to bribery or corruption are not collaborated even if they meet other requirements. Responsibility for making necessary research and evaluation within this scope primarily belongs to senior management. Internal Audit and Risk Department evaluates in its controls whether such issues are complied with.

5.2 Reaching Agreement with Companies and Business Partners

In contracts and agreements to be made with companies and business partners who have positive information and meet other criteria, the following conditions are included:

  • Ensuring full compliance with the principles indicated in the policy and other relevant regulations,
  • Employees' internalizing these principles and acting accordingly,
  • Ensuring its employees to receive trainings about the Policy in certain periods,
  • Reminding its employees regularly about notification obligations and encouraging them to notify in case they encounter such situations.

Provisions stating that relations will be terminated, in case these criteria are not complied with or in case a situation against the Policy occurs, need to be added in the contracts.

6. Our Policies and Procedures

6.1 Bribery and Corruption

PALMET is against all kinds of bribery and corruption. Accepting bribes or bribing can never be accepted under any purpose.

Business relationships with 3rd persons wishing to get business from PALMET through bribery or corruption have to be terminated.

6.2 Gift

A gift is a product generally given by customers or persons with which a business relationship is established as a means of thanking or commercial courtesy and which does not require a financial payment.

All kinds of gifts offered or given to third persons by PALMET must be offered in public, with good faith and unconditionally.

The same principles apply for accepting a gift and gifts that can not be regarded as commercial courtesy or expression of thankfulness must not be certainly accepted. In addition, even within this scope, gift acceptance must not become frequent and the Human Resource Department and Senior Management have to be informed about the gift by the employee who accept gift through his/her supervisor.

6.3 Facilitation Payments

The persons and institutions within the scope of this Policy must not offer facilitation payments to guarantee or speed up a routine transaction or process (obtaining authorization and license, obtaining a document, etc.) with government agencies.

6.4 Donations

Some legal restrictions have been imposed on donations and aids according to the Capital Market Law and relevant legislation which PALMET is subject to. The Donations made by PALMET  employees to the charity organizations with the amounts they collect apart from and independent of their works are out of the scope of PALMET. However, principles of is also valid at this point.

7. Correct Recording

Issues which PALMET must comply with in relation to accounting and recording system are regulated with legal regulations. Accordingly;

  • All kinds of accounts, invoices and documents belonging to relations with third parties (customers, suppliers, etc.) must be recorded and kept in a complete, accurate and reliable manner.
  • Falsification and distortion must not be made on accounting or similar commercial records related to any transaction.

8. Training and Communication

Our Anti-Bribery and Anti-Corruption Policy has been announced to employees of PALMET.

Trainings are important instruments for increasing awareness of employees. Within this scope, Human Resource Department designs training programs together with Internal Audit and Risk Department, Financial Affairs Department or Legal Department which are compulsory for all employees.

9. Notification of Policy Breaches

If opinion or suspicion exists that an employee or a person acting on behalf of PALMET is acting in breach of this Policy, the issue must be submitted to the Ethic Rule Advisor or Board of Directors.

PALMET encourages an honest and transparent approach; supports any employee or person acting on behalf of PALMET who expresses his/her sincere concerns with good faith, and keeps notifications secret. None of the employee shall be subject to pressure or punishment for the notification of Board about a violation of the Policy.

The companies and Business Partners from which goods and services are outsourced are also expected to remind their employees about the Ethics Line ( on a regular basis and encourage them to notify in case they encounter such situations. All notifications are kept confidential.  Ethic codes and anti bribery-corruption policies are discloused in corporate websites of Palmet Group Companies.

10. Policy Breaches

In cases which are or could be in breach of the Policy, necessary sanctions are implemented if inappropriate acts are detected.

In contracts made with the companies from which goods and services are bought and to whom goods and services are sold and with persons and institutions carrying out duties on behalf of PALMET, the provisions stating that if conducts, attitudes or activities in breach of Policy are detected, business will be terminated, need to be included and in case of breach of policy business shall be terminated.

Furthermore, those who do not comply with the legislation are liable to possible criminal sanctions.