Supplier Code of Conduct

Teknosa

Supplier Code of Conduct

Version 1.0

Date: September 2024

 

CEO Foreword

Dear business partners,

As Teknosa, we view our sustainable working principles and ethical values as the cornerstones of our business strategies, and governance issues is not just an obligation, but a requirement of our commitment to society, the environment, and all of our stakeholders.

In this regard, it is of great importance for Teknosa that the business conduct of all stakeholders in our supply chain are aligned with the principles of environmental responsibility, social justice, and good governance.

We are aware that you, our valued business partners, play a crucial role in helping us achieve our sustainability goals. Therefore, by sharing our Supplier Code of Conduct with you below, we aim to develop a common understanding and approach in the processes we work together.

We have full confidence that you will comply with these rules so that we can build a more sustainable future together. In this process, we aim to create a stronger and more responsible supply chain through mutual cooperation and continuous communication.

Thank you for being with us on this journey that will shape our future. We are grateful for your sensitivity and support on environmental, social and governance issues.

Best regards,

Sitara Sezgin

Teknosa General Manager

 

Introduction

Teknosa sees this Code of Conduct as an initiative covering the entire supply chain. In particular, we expect our suppliers with whom we work directly to accept and implement our Code of Conduct.

Code of Conduct is based on the understanding that a business shall operate in full compliance with applicable laws, rules and regulations in all its activities. This Code of Conduct supports going beyond legal compliance in the areas of social and environmental responsibility and business ethics, in line with internationally accepted standards and drawing on best practices in global supply chains. Compliance with the Code of Conduct shall not, under any circumstances, lead to a violation of applicable laws.

This Code of Conduct are derived from and respect internationally recognized standards, including the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the United Nations Declaration of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work and the Core Conventions.

The Supplier Code of Conduct defines the fundamental principles of our business conduct in five sections:

1. Labor
2. Health and Safety
3. Environment
4. Ethics
5. Management Systems

 

A.Labor

Business partners commit to respect the human rights of workers, and to treat them with dignity. This applies to direct and indirect suppliers, as well as all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. 

The labor standards are as follows:

1.Prohibition of Forced Labor

Any form of forced labor, including but not limited to bonded labor (including debt bondage) or forced or exploitative prison labor, slavery or human trafficking, is not permitted. This includes transporting, harboring, hiring, transferring or receiving persons for work or services through threat, coercion, duress, kidnapping or fraud. There shall be no unreasonable restrictions on employees’ freedom of movement within the facility, as well as unreasonable restrictions on their ability to enter or exit company-provided facilities, including employee dormitories or living quarters, if any. As part of the hiring process, all employees shall be provided with a written employment contract in their native language or a language they understand, that describes the terms and conditions of employment. Expatriate workers shall receive the employment contract prior to the employee’s departure from their country of origin, and no substitutions or changes to the employment contract shall be made upon arrival in the receiving country, unless this is done to comply with local law and to provide equal or better conditions. All work shall be voluntary, and workers shall be able to leave or terminate their employment at any time, without penalty, after a reasonable notice period, which shall be clearly stated in their employment contracts. Business partners shall retain documentation regarding all departing employees. Workers, agents, and sub-agents shall not retain or otherwise destroy, conceal, or seize government-issued identification or immigration documents, such as government-issued IDs, passports, or work permits. Notwithstanding the foregoing, employers may retain documents only if necessary to comply with local law. In such cases, employees shall never be denied access to their documents. Workers shall not be required to pay recruitment fees or other related fees to employer agents or sub-agents in order to be employed. If it is determined that such fees were paid by the employees, they shall be reimbursed to the worker.

2.Young Workers

Child labor shall not be used at any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age of completing compulsory education, or under the minimum age for employment in the country, whichever is greater. Workers under the age of 18 (Young Workers) shall not be employed in work that may endanger their health or safety, including night shifts and overtime. Business partners shall ensure that student workers are appropriately managed through appropriate student records, rigorous vetting of learning partners, and protection of student rights in accordance with applicable laws and regulations. Business partners shall establish an appropriate mechanism to verify the age of employees. The use of legitimate workplace learning programs that comply with all laws and regulations is encouraged. Business partners shall provide appropriate support and training to all student workers. In the absence of local laws, the wage rate for student workers, interns, and apprentices shall be at least the same as other entry-level workers performing equal or similar duties. If child labor is detected, assistance/corrective measures shall be provided.

3.Working Hours

Working hours shall not exceed the maximum hours set by local law. Further, a workweek shall not be more than 60 hours per week, including overtime, except in emergency or unusual situations. All overtime shall be voluntary. Workers shall be allowed at least one day off every seven days.

4.Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. All workers shall receive equal pay for equal work and qualifications. Employees shall be paid a higher hourly rate for overtime work. Employees shall be provided with a clear, timely wage statement for each pay period that includes sufficient information to verify compensation for work performed. All use of temporary, dispatch, and outsourced labor shall be within the limits of local law.

5.Non-Discrimination/Non-Harassment/Decent Treatment

Business partners shall commit to a workplace free of harassment and unlawful discriminationhere shall be no harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment. Companies shall not engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers. Workers shall be provided with reasonable accommodation for religious practices and disability. In addition, workers or potential workers should not be subjected to medical tests, including pregnancy or virginity tests, or physical exams that could be used in a discriminatory way. This was drafted in consideration of ILO Discrimination (Employment and Occupation) Convention (No.111).  

6.Freedom of Association and Collective Bargaining

Open communication and direct participation between workers and management is the most effective way to resolve workplace and compensation issues. Workers and/or their representatives should be able to openly share their ideas and concerns regarding working conditions and management practices with management without fear of discrimination, retaliation, intimidation or harassment. In accordance with these principles, Business Partners should respect the rights of all workers to form and join unions of their own choosing, to bargain collectively and to engage in peaceful assembly, as well as to refrain from such activities.

 

B.Health & Safety

Business partners recognize that a safe and healthy work environment increases the quality of products and services, consistency of business results, employee retention and morale, in addition to minimizing the incidence of work-related injuries and illnesses. Business partners also recognize that ongoing employee input and education are necessary to identify and resolve workplace health and safety issues.

Health and safety standards are as follows:

1.Occupational Health and Safety

for worker exposure to health and safety hazards (chemical, electrical and other energy sources, fire, vehicles and fall hazards, etc. ) should be identified, assessed and reduced using a hierarchy of controls. Where hazards cannot be adequately controlled by these means, workers should be provided with appropriate, well-maintained personal protective equipment and educational materials on the risks associated with these hazards. Gender-sensitive measures should be taken, such as not employing pregnant women and nursing mothers in working conditions that could be hazardous to them or their children and providing reasonable accommodations for nursing mothers.

2.Emergency Preparedness

Potential emergencies and incidents should be identified, assessed, and their impacts minimized by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, employee training, and drills.

Emergency drills should be conducted at least annually or as required by local law, whichever is more stringent. Emergency plans should also include appropriate fire detection and suppression equipment, clear and unobstructed exits, adequate exit facilities, contact information for emergency responders, and rescue plans. Such plans and procedures should focus on minimizing damage to life, the environment, and property.

3.Occupational Injuries and Illnesses

Procedures and systems for preventing, managing, monitoring and reporting occupational injuries and illnesses should be in place, including provisions to encourage worker reporting, classify and record cases of injuries and illnesses, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate workers’ return to work. Business partners should allow workers to remove themselves from imminent danger without fear of reprisal and not return until the situation has abated.

4.Industrial Hygiene

Workers’ exposure to chemical, biological and physical agents should be identified, assessed and controlled according to a hierarchy of controls. When hazards cannot be adequately controlled, appropriate, well-maintained personal protective equipment should be provided and used free of charge by workers. Business partners should provide safe and healthy working environments for workers and these environments should be maintained through continuous and systematic monitoring of worker health and work environments. Business partners should provide occupational health monitoring to routinely assess whether workers’ health is compromised by occupational exposures. Preventive occupational health programs should be ongoing and include educational materials on the risks of exposure to workplace hazards.

5.Physically Demanding Jobs

Situations where workers are exposed to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks, should be identified, evaluated, and controlled.

6.Machine Safeguarding

Production and other machinery should be evaluated for safety hazards. Physical guards, interlocks and barriers should be provided and properly maintained where machinery poses a risk of injury to workers.

7.Sanitation, Food and Housing

Workers shall be provided with ready access to clean toilet facilities, drinking water, and sanitary food preparation, storage, and eating facilities. Employee dormitories, if provided by a business partner or intermediary, should be kept clean and safe and should provide adequate emergency exits, hot water for bathing and showering, adequate lighting and adequate air-conditioning, adequate secured areas for storing personal and valuables, and reasonable ingress and egress privileges along with reasonable personal space.

8.Health and Safety Communication

Business partners shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Health information and training shall include content on specific risks to relevant demographics, such as gender and age, if applicable. Training shall be provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise any health and safety concerns without retaliation. 

9.Product and Consumer Safety

Business partners shall deliver products that meet all legal, industry, safety, quality and technical requirements such as locally relevant product labels. Adherence to rigorous safety protocols and standards is required throughout the entire product life cycle, from design and manufacturing to distribution. The safety of consumers shall always be prioritized by testing products for compliance with applicable safety regulations and industry standards. Additionally, suppliers shall provide accurate and comprehensive product information, including clear instructions for safe use and potential risks associated with the product. If products are found to not meet applicable requirements, the business partner shall notify Teknosa of any voluntary or mandatory product recalls and recalls, and actively work with Teknosa and regulatory authorities to recall and recall products.

 

C.Environment

Business partners recognize that environmental responsibility across all business functions is an integral part of producing world-class products or providing services. Business partners must identify their environmental impacts and minimize negative impacts on society, the environment and natural resources while protecting the health and safety of the public.

 The environmental standards are as follows:

1.Environmental Permits and Reporting

All required environmental permits (e.g., discharge monitoring), approvals and licenses shall be obtained, maintained, and kept current, and their operating and reporting requirements shall be complied with.

2.Pollution Prevention and Resource Conservation

Emissions, discharges of pollutants, and waste generation shall be minimized or eliminated at the source or by adding pollution control equipment, modifying production, maintenance, and facility processes, or other methods. Natural resources, including water, fossil fuels, minerals and unprocessed forest products, should be conserved through modification of production, maintenance and facility processes, material substitution, reuse, conservation, recycling or other means. Business partners are encouraged to re-use own materials in a circular manner, design repairable products and provide spare parts where possible.

3.Hazardous Materials

Chemicals, wastes and other materials that pose a hazard to humans or the environment shall be identified, labelled and managed to ensure they can be safely handled, transported, stored, used, recycled or reused and disposed of. Hazardous waste data shall be tracked and documented.

4.Solid waste

Business partners shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste (non-hazardous). Waste data shall be tracked and documented.

5.Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances and combustion by-products from operations should be characterized, routinely monitored, controlled and treated as necessary prior to discharge. Ozone depleting substances should be effectively managed in accordance with the Montreal Protocol and applicable regulations. Business partners shall conduct routine monitoring of the performance of its air emission control systems. 

6.Material Restrictions

Business partners shall adhere to all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal. 

7.Water Management

Business partners shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination and seeks to limit the negative impact on affected communities. All wastewater shall be characterized, monitored, controlled, and treated as required prior to discharge or disposal. Business partners shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance. 

8.Energy Consumption and Greenhouse Gas Emissions

Business partners shall establish and report an absolute corporate-wide GHG (greenhouse gas) reduction target. Energy consumption and all Scopes 1, 2, and significant categories of Scope 3 greenhouse gas emissions shall be tracked, documented. Business partners should seek ways to improve energy efficiency and minimize their energy consumption and GHG emissions. Business partners are encouraged to implement carbon pricing internally to incentivize emissions reductions.

9.Biodiversity

Business partners are encouraged to understand their impact on nature and their dependence on nature. Business partners are encouraged to be aware of their impacts resulting from their direct activities and from high-impact areas of their supply chain e.g. raw material sourcing.

 

D.Ethics

To meet social responsibilities and to achieve success in the marketplace, Business partners and their agents shall uphold the highest standards of ethics including the following: 

1.Business Integrity

The highest standards of integrity shall be observed in all business dealings. Business partners shall have a zero-tolerance policy prohibiting all acts of bribery, corruption, extortion, embezzlement and tax evasion.

2.No Improper Advantage

Bribes or other means of obtaining an improper or undue advantage shall not be promised, offered, authorized, given or accepted. This prohibition includes promising, offering, approving, giving or accepting anything of value, directly or indirectly through a third party, to obtain or retain business, to refer business to any person or otherwise to gain an improper advantage. Monitoring, record keeping and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

3.Disclosure of Information

All business dealings shall be transparently performed and accurately reflectedthe business partner’s commercial books and records. Information regarding the business partner’s workforce, health and safety, environmental practices, business activities, structure, financial situation and performance shall be declared in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is unacceptable.

4.Intellectual Property

Intellectual property rights shall be respected. Technology and know -how transfer shall be made in a way that protects intellectual property rights; customer and supplier information shall be safeguarded. 

5.Fair Business, Advertising and Competition

Standards of fair business, advertising, and competition shall be upheld. 

6.Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity, and protection of supplier and employee whistleblowers¹ shall be maintained, unless prohibited by law. Business partners shall have a communication process for their personnel to be able to raise any concerns without fear of retaliation. 

7.Responsible Sourcing of Materials

Business partners shall adopt a policy regarding the source and chain of custody of tantalum, tin, tungsten, gold and cobalt in their manufactured products and conduct due diligence to ensure that they are obtained in a manner that is reasonably certain consistent with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Sourcing of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognised due diligence framework.

8.Privacy and Data Security

Business partners shall commit to protecting the reasonable privacy expectations regarding the personal information of everyone they do business with, including suppliers, customers, consumers and employees. Business partners shall comply with privacy and information security laws and regulatory requirements when collecting, storing, processing, transmitting and sharing personal information. Business partners shall implement robust measures to protect confidential data and any data breach or security breach incidents shall be reported to Teknosa immediately.

9.International Trade Law

Business partners shall comply with all applicable international trade laws and regulations applicable to products and services delivered to Teknosa. Every possible measure should be taken including prevention of business with a sanctioned country, company, entity or person.

 

E.Management Systems

Business partners shall adopt or establish a management system with a scope that is consistent with the content of this Code of Conduct. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the business partner's activities and products; (b) compliance with this Code of Conduct ; and (c) identification and mitigation of operational risks related to this Code of Conduct. It shall also facilitate continual improvement.

The management system should include the following elements:

1.Company Commitment

Business partners shall establish human rights, health and safety, environmental and ethics policy statements affirming Business partner’s commitment to due diligence and continual improvement, endorsed by executive management.

2.Management Accountability and Responsibility

Business partners shall clearly identify senior executive and company representative(s) responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management systems on a regular basis. 

3.Legal and Customer Requirements

Business partners shall adopt or establish a process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code of Conduct.

4.Risk Assessment and Risk Management

Business partners shall adopt or establish a process to identify the legal compliance, environmental, health and safety², labor practice and ethics risks, including the risks of severe human rights and environmental impacts, associated with Business partner’s operations. Business partners shall determine the relative significance for each risk and implement appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance. 

5.Improvement Objectives

Business partners shall establish written performance objectives, targets and implementation plans to improve the Business partner’s social, environmental, and health and safety performance, including a periodic assessment of Business partner’s performance in achieving those objectives. 

6.Training

Business partners shall establish programs for training managers and workers to implement Business partner’s policies, procedures, and improvement objectives and to meet applicable legal and regulatory requirements. 

7.Communication

Business partners shall establish human rights, health and safety, environmental and ethics policy statements affirming Business partner’s commitment to due diligence and continual improvement, endorsed by executive management. Policy statements shall be made public and communicated to workers in a language they understand via accessible channels. 

8.Worker/Stakeholder Engagement and Access to Remedy

Business partners shall establish processes for ongoing two-way communication with workers, their representatives, and other stakeholders where relevant or necessary. The process shall aim to obtain feedback on operational practices and conditions covered by this Code of Conduct, and to foster continuous improvement. Workers shall be given a safe environment to provide grievance and feedback without fear of reprisal or retaliation. 

9.Audits and Assessments

Business partners shall conduct periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code of Conduct, and customer contractual requirements related to social and environmental responsibility. 

10.Corrective Action Process

Business partners shall establish a process for the timely correction of deficiencies identified through internal or external assessments, inspections, investigations and reviews.

11.Documentation and Records

Business partners shall create and maintain documents and records to ensure regulatory compliance and compliance with company requirements, while maintaining the confidentiality necessary to protect privacy.

12.Supplier Responsibility

Business partners shall communicate the requirements of the Code of Conduct and the Teknosa Ethics Violation Reporting Line information below to their employees and establish a process to monitor supplier compliance with the Code of Conduct.

 

Teknosa Ethics Violation Reporting Line

E-mail               : [email protected]

Phone               : 0216 468 3602

Address            : Internal Audit Senior Directorate, Carrefoursa Plaza, Cevizli Neighborhood, Tugay Yolu Street. No:67 B Block Post Code: 34846 Maltepe/Istanbul