Etasis Elektronik Tartı ve Sistemler Sanayi ve Ticaret Anonim Şirketi (“Etasis”), conducts all its activities in compliance with all applicable and binding national and international laws and legislation. In the same vein, Etasis expects all of its stakeholders to act in compliance with Etasis mission, vision & values, Etasis Compliance Policy and all binding legislation.
Etasis, encourages you to disclose any unethical behavior or any conduct that is contrary to Etasis company rules or the law, by using the following Disclosure Mechanism.
- What is The Purpose of This Policy?
Etasis Ethical Notification Policy (“Policy”) defines the criteria and notification methods for reporting matters that may violate compliance with all responsibilities, especially;
- Etasis Compliance Policy[1] and company rules,
- Labor Law No. 4857, Standards of International Labor Organization (ILO) and applicable and binding national and international legislation,
- Applicable regulations, bylaws and communiqués
This Policy aims to provide information regarding the following matters:
- People who may make a notification
- Matters for disclosure
- Disclosure channels
- Responsibilities of Etasis
- Who is Concerned by this Policy?
Within the scope of this policy, any person mentioned below, who is aware of or affected by any unethical or unlawful situation, is entitled to report. Such a cases must be suspected to have occurred within Etasis or within Etasis’ suppliers and constitute human rights violations or violations of any environmental obligations.
- Etasis employees
- Etasis suppliers
- Etasis customers
- All other third-parties (consultants, intermediaries, agents, etc.)
- What Are the Etasis Disclosure Channels?
Etasis encourages you to report any suspected actions that may constitute a violation under this Policy or applicable national or international legislation through the disclosure channels listed below:
Telephone: You may call (+90) 222 236 15 53 or (+90) 531 783 56 13.
[1] See. https://www.etasis.com.tr/en/sanctions-and-export-controls-compliance-policy/
E-mail: You may send an e-mail to “etik@etasis.com.tr”.
- What Matters Should You Report?
| Appropriate Matters for the use of Disclosure Channels | Inappropriate Matters for the use of Disclosure Channels |
| National and International Sanctions and Export ControlsCorruption, bribery, money laundering, terrorism financingConflict of InterestAbuse of trust, misconduct, and fraudulent transactions,Any violation of applicable legislationForgery of documents, false claims in digital or physical mediaViolation regarding cybersecurity and personal data protectionVerbal or physical harassment, insult,Psychological harassment (mobbing)Assault, injuryDiscrimination and retaliation Violations of occupational health & safety rulesEmployment of child laborViolations of the right to form or join a trade unionForced LaborWorking hours and wages contrary to the LawPractices that cause unlawful waste management, water and air pollution in the factoriesOther violations of similar national & international legislation and Etasis internal policies, as well as any other actions that may pose financial, legal, ethical, or reputational risks to Etasis. | Personal relationshipsPromotion, bonus, salaryAnnual leave, National Holiday and General Holiday Leave, Compassionate Leave or other leave-related mattersMatters regarding the cafeteria, shuttle service etc. For any requests, questions, or comments regarding these or similar matters related to employee personal rights, you are required to directly contact the Demet Çetin. Etasis Disclosure Channels are designed exclusively for reporting matters that may be unethical or unlawful. However, if you believe that an unlawful practice is being carried out in relation to the matters mentioned above, you may use the Disclosure Channels. |
Example of a Case to Report to the Disclosure Channel:
A logistics department employee noticed that some Etasis products were being indirectly shipped to a country subject to export restrictions through a different country. Considering that this situation may violate international sanctions, the employee reported the situation as quickly as possible through the Disclosure Channel.
Example of a Case Not to Report to the Disclosure Channel:
An employee felt that their bonus was insufficient and that they were not being adequately rewarded for their performance. Considering this situation unfair, they wanted to file a report to Disclosure Channel. However, matters related to bonuses and salaries are not considered ethical violations, but a matter concerning personal rights; thus, they should be evaluated directly with the Human Resources Officer.
- What to Consider When Making a Disclosure?
While reporting, the person submitting a disclosure report is expected to provide sufficient and detailed information.
In cases where the disclosures we intend to make regarding ethics and compliance violations that we are aware of or are subject to are not supported by clear and direct evidence, all evidence that can be provided is essential in order to inquire and investigate the matter subject to the disclosure, to correctly understand it, and to evaluate it in a transparent, impartial and fair manner.
Therefore, it is expected that, to the extent possible, disclosure reports should include answers to the following questions:
- The suspected act constituting an ethical or compliance violation; where and when the action occurred, whether it is still ongoing, and whether it has occurred before,
- The names of the suspected person(s) or individual/institutions involved in the incident,
- When the person reporting became aware of the incident,
- Whether any other person is aware of the incident, and if so, whether any action has been taken,
- Whether there is any existing evidence, and if so, where such evidence is contained,
- If available, any concrete evidence such as documents, invoices, emails, etc. should be attached to the disclosure report.
Etasis encourages the person who suspects a violation to make a disclosure even in cases where the mentioned information is not fully and clearly available.
- Responsibilities and Commitments of Etasis
- Confidentiality:
Etasis encourages all its employees or third parties acting for or on behalf of Etasis to express their opinions and suspicions in good faith.
Etasis maintains the confidentiality of all disclosures. In case of any investigation on information or documents, a correspondence will be conducted with care to ensure the anonymity of the reporting individual within the organization. Etasis expects the same level of sensitivity regarding confidentiality from the reporting person.
Until the finalization of the evaluation of the events subject to notification or a further notification is provided by Etasis, no information should be communicated to anyone intra-organizational or non-organizational regarding the event subject to the disclosure.
- Prevention of Retaliation:
Etasis is dedicated to ensure that person making the disclosure under this Policy is not subjected to any form of discrimination, mistreatment, social or psychological pressure, or any other type of retaliation as a result of their reporting.
In this respect, Etasis adopts the principle of “zero tolerance against retaliation”. Under this principle, an employee who makes a report shall not, with or without justification, be subject to any of the following actions as a result of their disclosure:
- Termination of employment agreement.
- Change of working conditions.
- Suspension from work.
- Forced to use paid or unpaid leave.
- Any other penalty, sanction, or disciplinary action or similar punitive act.
Etasis does not subject or tolerate any employee to any form of pressure, punishment or retaliation for reporting a suspected ethics and compliance violation.
Etasis exercises the utmost diligence to protect the physical and mental safety of the reporting person.
Etasis fully supports ethics reports made in honesty, transparency, and good faith, and protects those who make such reports.
Non-compliance with the rules regarding the prevention of retaliation by other employees constitutes a violation of this Policy. In such cases, disciplinary actions shall be taken by the Etasis Board of Directors.
- Management of Disclosure Reports:
Etasis takes all necessary measures and exercises due diligence to ensure that reports are received, assessed based on objective criteria, concluded without delay, and relevant parties are duly informed.
The assessment and conclusion of disclosure reports submitted under this Policy are the responsibility of the Ethics and Compliance Committee.
- Document Updating, Storage and Publication:
Etasis ensures that the most up-to-date version of this Policy is in force and publicly available.
This Policy, along with its previous revisions, is retained indefinitely within Etasis document management systems.
In case a revision to this Policy is required, the Ethics and Compliance Committee is responsible for conducting the necessary revisions and announcing the revision to all parties affiliated with this Policy.
| Revision | Effective Date | Notes |
| 1 | ../04/2025 |
