EMAK’s Code of Conduct  

  1. Why do we have this Code of Conduct?

This Code of Conduct sets out the standards of behavior and business conduct we expect of all Emak employees. We expect these standards, underpinned by the principle of doing the right thing, to be adopted by individuals whenever they are performing their day-to-day duties as employees of Emak, or when they are representing Emak. All employees must take personal responsibility for ensuring that our commitment to sound and ethical business conduct is delivered. Who does the Code of Conduct apply to? This Code of Conduct applies to all subsidiary companies of Emak and their directors, officers, managers and employees, including temporary workers. What is required of me? You must read and understand this Code and take personal responsibility for complying with it at all times by doing the right thing when dealing with your colleagues and other stakeholders. If you are a manager or supervisor, you have an added responsibility to lead by example. You must ensure that members of your team understand this Code, that they are able to seek guidance when required and that any issues of concern which are reported to you are dealt with in the proper manner. This Code provides a framework and guidance for ethical conduct but is not designed to cover all situations which you may encounter in your day-to-day activities. If you are faced with a decision about an ethical matter and are unsure what to do, you should ask yourself the following questions:

  • What is the right thing to do?
  • Is it legal, decent, fair and honest? • How would it look if the issue was reported in the newspaper?
  • Would I feel comfortable explaining this in a court?
  • Am I personally comfortable with this?

Often, a common-sense approach, using these principles as guidelines, will be the right approach. However, if you remain concerned, you should seek further advice. You should report any issues or concerns you may have regarding an actual or potential breach of this Code. What about different laws and business practices in different countries? Emak is committed to complying with the laws and business regulations in each of the countries in which we operate. The Code applies everywhere we operate. If any local laws or business practices permit a lower standard of behaviour, then we operate to the standards set out in this Code. Where can I get further guidance? If you require further guidance about what to do in a particular situation or about any issue which may arise, you can seek help from your line manager or address an email the Group Compliance team (info@emak.com.tr). What do I do if I am concerned about a breach of the Code of Conduct? If you believe that you have experienced or witnessed behavior which does not meet the standards required by the Code, you have a responsibility to do something about it. You may first wish to discuss the matter informally with your line manager. And send an email officially or anonymously if you wish. If you believe you are being treated unfairly as a consequence of raising a concern, you should report the matter. Any such claims will be investigated thoroughly. Anyone who is found to engage in retaliation or reprisal will be considered to be in breach of this Code. What if something goes wrong? Sometimes things can go wrong. We can all make mistakes. So, if you notice something has gone wrong, what do you do? You must not ignore it. Our policy requires you to report it. Ignoring it does not solve it – it may make things worse. What are the consequences of breaching the Code of Conduct? Emak regards any failure to comply with the Code as a serious issue. Accordingly, breaches of the Code may be dealt with as misconduct and Emak may take disciplinary action, up to and including dismissal.

    • Health and safety

Safety is at the heart of everything we do and there is a need to ensure the safe and responsible operation of our business at all times. Nothing is so urgent that it cannot be done safely. Our principles We believe that all incidents and injuries are preventable and that all employees have the right to return home safely at the end of every working day. We aim to ensure we develop a proactive health and safety culture through learning and continuous improvement. Each of us is responsible for acting in a way that protects ourselves and others. You will:

  • take steps to understand and comply with applicable health and safety rules and procedures, both for your own safety and the safety of others;
  • work in a way that protects the health and safety of those you come into contact with;
  • be aware of the risks and hazards in your workplace and seek to reduce the potential for harm;
  • ensure that you and members of your team have the skills and resources required to perform your roles safely;
  • commit to promoting and embracing a positive health and safety culture;
  • report potential hazards and concerns through the appropriate channels and take action to intervene and stop work if you consider you or others may be at risk; and
  • comply at all times with all applicable health and safety requirements.

You will not:

  • ignore or circumvent health and safety rules and procedures;
  • take unnecessary risks; or
  • put others in danger as a result of your actions.


  • The environment

  We are committed to managing our environmental impact to a high standard and maintaining the sustainability of our business.   Our principles

  • EMAK believes that it is essential to minimise the environmental impact of its operations in order to secure the long-term future of the business.

You will:

  • comply with environmental laws, policies and procedures;
  • control pollution;
  • minimise waste at our sites and recycle wherever possible;
  • consume resources efficiently;
  • use materials that minimize the environmental impact of our operations;
  • minimise our carbon footprint;
  • source materials in a responsible way.


  • Workplace behaviors

We recognize the valuable contribution of our employees and we aim to treat people fairly and provide an inclusive working environment. We also recognize the benefits of diversity and that a diverse workforce produces better results.   Our principles Emak is committed to providing equal opportunities for all employees, irrespective of race, nationality, gender, sexual orientation, marital status, gender identity, religion, political belief, disability, age or other protected categories. We aim to create a diverse and inclusive working environment in which all employees should feel respected and valued and in which they are able to make the best use of their skills, free from discrimination or harassment. You will:

  • treat your fellow employees, and others you meet, whilst conducting business, fairly and with dignity and respect at all times;
  • have consideration and regard for the beliefs and opinions of others, even when they may differ from your own;
  • support diversity within the workplace;
  • ensure that the promotion of employees is based on merit;
  • speak up if you witness any individual being subjected to discrimination, bullying or harassment; • employ only workers who meet the minimum applicable legal age requirement; and
  • set employees’ working hours and pay in compliance with all applicable laws

You will not:

  • discriminate against employees, or any other individuals you meet whilst conducting business, on the grounds of race, nationality, gender, sexual orientation, marital status, gender identity, religion, political belief, disability, age or otherwise;
  • display behavior which offends, humiliates or threatens others; or
  • engage in or support the use of forced or compulsory labour.


  • Privacy and personal data

We are committed to being transparent about how we collect and use the personal data of employees and others and to meeting our data protection obligations. Our principles We respect the personal privacy of employees in accordance with applicable data protection laws and acknowledge that employees and others have rights regarding the handling of their personal data. You will:

  • process personal data only in accordance with relevant data protection laws; and
  • ensure that personal data in our possession is treated in a confidential and secure manner and is safeguarded from loss, disclosure or misuse.

You will not:

  • access personal data for any reason other than a legitimate legal or business reason; or
  • transmit personal data to anyone in the organization or a third party without proper authorization and a legitimate legal or business reason for doing so.
  • Use of IT systems

We use our IT systems appropriately and responsibly. Our principles We will use our IT systems and equipment for their intended purpose of promoting effective communication and working practices within our business. We will safeguard IT assets in our possession from loss, disclosure or misuse. You will:

  • comply with all applicable laws, policies and procedures governing the use of our IT systems;
  • take appropriate measures to prevent access to our IT systems by complying with our information security requirements; and
  • immediately report any loss of equipment, unauthorised access or other suspicious activity involving our IT systems of which you become aware.

You will not:

  • use our IT systems for any activity which may be illegal, offensive, discriminatory, unethical or immoral; or
  • destroy or cause intentional damage to our IT assets and data stored thereon (except as properly authorized).
  • Conflicts of interest

We manage conflicts of interest within the business properly and with integrity.   Our principles We will identify any relationships with other employees, clients, suppliers or competitors etc. where our personal interests (or those of a close relative) conflict or may appear to conflict with those of Emak and will ensure these are disclosed and managed appropriately. You will:

  • promptly disclose to your line manager any potential conflicts of interest and update the disclosure if necessary; and
  • seek approval prior to entering into any relationship which may affect your ability to make objective business decisions.

You will not:

  • have a directorship, substantial shareholding or other interest in a company with which Emak does business without prior approval;
  • perform any work in your spare time for a third party with which Emak does business or which is a competitor to Emak;
  • be involved in activities for your own personal gain which conflict with Emak’s business interests;
  • use Emak’s assets to undertake work for, or provider services to, a third party for your own personal gain; or
  • employ or appoint a partner or relative to perform services for Emak for reward.
    • Complying with laws and regulations

We are committed to conducting our business in accordance with applicable laws and in a responsible manner. Our principles We must comply with all applicable laws and regulations. You will:

  • ensure that you understand the relevant legal requirements which apply to your role or business, by obtaining appropriate advice if necessary;
  • apply our standards, even in situations where the applicable or local law is less restrictive than those standards; and
  • seek advice if you become aware of any breaches of laws or regulations by our business or our employees.

You will not:

  • ignore rules for expediency;
  • turn a blind eye if you know or suspect others may be breaking the law; or
  • cut corners on cost grounds.
  • Anti-bribery and corruption (including gifts and hospitality)

Emak adopts a zero-tolerance approach to bribery and corruption. We will not give or accept gifts or hospitality which may improperly influence our or others’ business decisions or outcomes and which may be construed as a bribe. Our principles Bribery is a criminal offence. Paying or conspiring to pay, soliciting or accepting bribes is against the law. We require our employees and all third parties acting on our behalf to conduct business honestly and with integrity. We will not under any circumstance pay a bribe to, or accept a bribe from, any individual, organisation and/or public official in order to gain or retain any business advantage or for any other improper purpose. We recognise that the courtesy of giving or receiving gifts and hospitality of modest value in the normal course of business, where permitted by law, is acceptable in principle, but under no circumstances must the givingor receiving be done with a view to the recipient being influenced to act improperly or to obtaining any form of improper advantage. We do not make political contributions or donations. You will:

  • comply at all times with our policies and procedures which are designed to prevent bribery;
  • speak up if you become aware of any potential or actual breach of anti- bribery laws or regulations or our own Anti Bribery and Corruption (including Gifts and Hospitality) Policy;
  • ensure that all employees and third parties acting on our behalf understand Emak’s zero tolerance approach to bribery and corruption;
  • only accept or offer gifts or hospitality of a modest value, when it is lawful and customary practice to do so; and
  • ensure that any gifts or hospitality are duly authorised, and recorded as necessary in a timely manner, in accordance with our gifts and hospitality rules.

You will not:

  • tolerate or condone bribery or any other type of corrupt activity;
  • offer, promise or give, solicit, agree to receive or demand any financial or other advantage, whether directly or indirectly, in order to induce or reward improper behaviour;
  • offer or make facilitation payments;
  • pay a bribe or participate in any other corrupt activity, regardless of any local custom or practice, for the purpose of winning or retaining business or obtaining an advantage in the conduct of business.;
  • offer, promise or give any gifts or hospitality which may be (or may be misconstrued as) a personal reward for the recipient, intended to influence the recipient to act improperly or to reward improper behaviour on the part of the recipient;
  • request, agree to receive or accept any gifts or hospitality which you believe are intended to influence improper behaviour or decisions or which would or could impose an obligation on you to treat another third party favourably; or
  • make political donations or contributions on behalf of Emak.


  • Anti-competitive behaviour

We will comply with competition laws. Our principles Emak aims to compete fairly. We will not resort to anti-competitive behaviour nor will we tolerate such behaviour from employees or anyone acting on our behalf. You will:

  • comply with relevant competition laws;
  • require all employees who have joined Emak from a competitor, customer or supplier to respect the confidential information of their previous employer; and
  • speak up if you become aware of any potential or actual breach of competition laws.

  You will not:

  • obtain or use information on competitors, clients and suppliers which has been obtained by illegal or disreputable means;
  • discuss pricing or bid strategies with our competitors; or
  • enter into discussions with competitors about sharing or restricting access to markets or clients.
  • Financial management and reporting


  • We will maintain proper and accurate business and financial records.

Our principles

  • utilise appropriate internal controls, including Internal Audit, to enable the accurate reporting of the Group’s results.
  • You will not:
  • deliberately make a false or inaccurate entry in any company records or books of account;


  • Protecting our reputation

  We will protect Emak’s reputation.   Our principles  

  • We recognise that Emak’s reputation is one of its key assets and we will not take any action or engage in any behaviour, either at work or outside of the workplace, which may cause reputational damage to Emak or any of its employees.

You will:

  • act in a way which protects and promotes Emak’s good reputation at all times.

  You will not:

  • make disparaging or damaging remarks about Emak or any of its employees or stakeholders, whether verbally, in writing, electronically via email or the internet or via social media; or
  • engage in any activities outside of work which may reflect adversely on the reputation of Emak.


  • Confidential information


  • We are committed to protecting Emak’s confidential information.

Our principles

  • We will take all necessary steps to protect Emak’s confidential information and we will not use it for our personal benefit or for any illegal purpose. We will treat any such information provided to us by third parties with an equivalent level of care.

You will:

  • keep confidential information protected and secure at all times;
  • respect any conditions imposed by third parties on the use of their confidential information;
  • ensure confidential information is only shared on a “need to know” basis and, in the case of a third party’s confidential information, with their consent; and
  • promptly report any unintended disclosure of confidential information.
  • You will not:
  • disclose confidential information to any third party without entering into an effective confidentiality agreement.
  • We will ensure that our financial transactions are recorded in a timely manner and that our assets and liabilities are properly reflected in our financial records, in accordance with relevant accounting standards applicable to and adopted by Emak.
  • We are committed to the prevention and detection of fraud and will report fraudulent activity, which may be a criminal offence, to the relevant
  • We will not support activities designed to evade taxes.

  You will:  

  • be transparent with regards to all financial transactions; and
  • artificially manipulate the financial results of a period to show a position which is better than actual; or
  • facilitate or assist in tax evasion by a third party.


  • Community investment

We acknowledge our commitment to ensure the responsible operation of our business, having regard to the wider community. Our principles We recognise that each Emak business has an important role to play in its local community and we therefore encourage community interaction for the benefit of Emak and its stakeholders. We support charitable organizations which are directly linked to benefit people in our local areas and communities. You will:

  • only make charitable donations in full compliance with all applicable laws and regulations and our Anti Bribery and Corruption (including Gifts and Hospitality) Policy;
  • ensure all charitable donations are properly recorded; and
  • encourage and support employees who wish to undertake voluntary work in their community.

You will not:

  • make any charitable donations to any expressly prohibited organisations.
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