Prevention of Forced Labour and Voluntary Employment Policy and Procedure

1. PURPOSE

The purpose of this policy and procedure is to ensure that no employee at the workplace is made to work by force, under pressure, by threat, through indebtedness, through the confiscation of identity documents or otherwise against their free will; to safeguard the principle of voluntary employment; and to ensure compliance with national legislation and international labour standards.

The company accepts that all employees work of their own free will and strictly prohibits all forms of forced labour.

2. SCOPE

This procedure covers all employees, temporary workers, subcontractor employees, interns, foreign national employees, subcontractor firm personnel, managers involved in recruitment processes, the Human Resources Department, and supplier and service provider firms.

3. LEGAL BASIS

This procedure has been prepared on the basis of the following legislation and international standards:

• Labour Law No. 4857
• Turkish Code of Obligations No. 6098
• Social Insurance and Universal Health Insurance Law No. 5510
• ILO Forced Labour Convention No. 29
• ILO Abolition of Forced Labour Convention No. 105
• Universal Declaration of Human Rights

4. DEFINITIONS

4.1 Forced Labour

Making a person work against their own free will by means such as physical pressure, psychological pressure, threat, blackmail, indebtedness, the threat of wage deductions, withholding identity documents or passports, the threat of dismissal, or restriction of freedom of movement.

4.2 Voluntary Employment

The employee starting work of their own free will, continuing the employment relationship, and being able to leave employment in accordance with statutory notice periods.

5. POLICY PRINCIPLES

The company strictly prohibits the following practices: forced labour, compulsory labour, bonded labour, work within the scope of human trafficking, confiscation of an employee's identity documents, passport or original documents, use of wages or entitlements as a means of pressure, preventing an employee from leaving employment, applying physical or psychological pressure, making overtime compulsory, and making people work through threats or punishment.

6. IMPLEMENTATION PRINCIPLES

6.1 Recruitment Process

• All employees are recruited voluntarily.
• Employment contracts are prepared in a language the employee can understand.
• Duties, wages, working hours and rights are clearly explained to the employee upon recruitment.
• No deposit, security or coercive payment is requested from employees during recruitment.
• Originals of employees' identity documents, passports or personal documents are not held by the company.
• Where necessary, only photocopies are taken and kept in the personnel file with the employee's consent.

6.2 Working Hours and Overtime

• Overtime is worked on a voluntary basis.
• Employee consent is obtained for overtime.
• Employees may refuse overtime within the scope of their legal rights.
• No pressure may be placed on employees on account of overtime.
• Working hours are planned in accordance with national legislation.

6.3 Wage Payments

• All wages are paid on time and on the record, as required by law.
• No unlawful deduction may be made from wages.
• Wages may not be used as a means of pressure or punishment.
• Employees are issued wage slips regularly.

6.4 Right to Leave Employment

• Employees have the right to leave employment in accordance with statutory notice periods.
• An employee's departure may not be prevented by physical, economic or psychological means.
• The personal documents and entitlements of a departing employee are delivered in accordance with the legislation.

6.5 Foreign National Employees

• Work permits for foreign employees are obtained lawfully.
• Passports or identity documents may not be withheld by the company.
• No pressure may be placed on foreign employees on grounds of language, country of origin or status.

7. COMPLAINT AND REPORTING MECHANISM

Employees may report confidentially through the following channels:

• Human Resources Department,
• Ethics Reporting Line,
• E-mail notification,
• Written petition,
• Direct report to managers.

The company:

• Protects the employee who makes a report,
• Prohibits retaliation,
• Assesses reports in confidence,
• Carries out the necessary investigation,
• Initiates corrective action for identified non-conformities.

8. AUDIT AND MONITORING

The company:

• Carries out regular internal audits,
• Assesses subcontractors and suppliers in terms of social compliance,
• Monitors recruitment processes,
• Tracks working hours and overtime,
• Analyses forced labour risks periodically.

9. RESPONSIBILITIES

Human Resources Department

• To ensure that recruitment processes are carried out on a voluntary basis,
• To check employee documentation processes,
• To operate the complaint mechanism,
• To organise training.

Managers

• Not to place pressure on employees,
• To comply with the principle of voluntariness in overtime processes,
• To report suspicious situations to Human Resources.

Employees

• To report violations of rights,
• To act in accordance with policies and procedures.

10. TRAINING

The company provides regular awareness training on human rights, prevention of forced labour, ethical working principles and employee rights.

11. NON-CONFORMITY AND CORRECTIVE ACTION

The following may be applied to persons acting contrary to this procedure:

• Internal investigation,
• Disciplinary process,
• Contractual sanction,
• Legal proceedings where deemed necessary.

12. ENTRY INTO FORCE

This procedure enters into force upon the approval of senior management.

All employees, subcontractors and relevant parties are obliged to comply with the procedure.