“ANTI-CORRUPTION AND ANTI-BRIBERY POLICY” OF KESKIN GUNGOR CUSTOMS CONSULTANCY

Keskin Güngör Customs Consultancy (KG) believes that business ethics and culture is an important value to grow and develop countries and world’s economy within the framework of sound foundations. Anti-Corruption and Anti-Bribery is one of the priorities of companies and countries desiring to create sound economies. We have prepared our “Anti-Corruption and Anti-Bribery Policy” within the framework of both laws of our country and laws and legislations of the countries of the companies served by us (The US Foreign Corrupt Practices Act- FCPA), UK Bribery Act- UKBA etc.) in order to encourage a fair and competitive commercial environment and for our corporate reputation.

When we carry out our activities, we are obliged to comply with the laws and regulation regarding bribery and corruption between companies and governmental authorities. Our “Anti-Corruption and Anti-Bribery Policy” clearly reveals our intention and obligation to always act in an honest manner in all our commercial activities.

OUR OBLIGATIONS

Bribery and corruption is forbidden in transactions and commercial activities between KG and private authorities, state authorities and all other parties. In particular, prohibitions are applied to bribery, kickback, improper gifts to state officials and trade entities including employees of state authorities or entities under the state’s control with whom ordinary commercial activities are conducted and to all efforts and facilitating payments to affect trade improperly.

KG employees and third persons acting on behalf of KG must comply with all anti-corruption and anti-bribery laws and legislations on a global basis (including FCPA in the US and UKBA in the United Kingdom) including the laws of the Republic of Turkey in particular.

SCOPE

“Our Anti-Corruption and Anti-Bribery Policy” covers:

  • Bribery, Commission or Similar Corrupt Payments
  • Facilitating Payments
  • Getting Improper Advantage
  • Third Party relationships.

DEFINITIONS

BRIBERY, COMMISSION OR SIMILAR CORRUPTION PAYMENTS

It refers to cash payment, gift, credit, reward and similar interest given or received, directly or indirectly, to/from a public official, governmental or commercial real or legal person in violation of the laws and ethical rules for affecting his action or omission in consideration of a service, giving or not giving a new business, maintaining or cancelling the current business and influencing his decision to get unfair and improper advantages in commercial relationships.

FACILITATING PAYMENTS

It is also a bribery as per KG Policy. Money, kickback paid or present given to a Public Official to obtain visa, work permit, accelerate routine and compulsory activities in inspections and controls of company vehicles or non-commercial corporate transactions or cooperate with a Public Official on any matter required by him.

GETTING IMPROPER ADVANTAGE

Getting advantage by improperly affecting decision of a public institution or business enterprise to purchase KG services.

PUBLIC OFFICIAL

  • An authorized person of a public institution, elected or appointed,
  • Academicians working at the state universities,
  • Healthcare services specialists working at public health institutions supported by the state,
  • Authorized person from a political party, a candidate for a public function, employees acting on behalf of such persons, consultants
  • Employee of an entity or institution under the state control, partially or fully and working to the benefit of the public are considered as a PUBLIC OFFICIAL.

THIRD PARTY

Persons and entities serving to KG, affecting service provided by KG to its customers. Consultants, auditors, data processing company, financial advisor, carriers, bonded warehousemen.

OUR ANTI-CORRUPTION AND ANTI-BRIBERY POLICY FOR RELATIONS WITH THE PUBLIC AND PUBLIC OFFICIALS

A KG employee and Third Party authorized to act on behalf of KG may not make a payment or promise a payment, directly or indirectly, in order to influence a Public Official to ensure KG to obtain the business, maintain its current business, take an action or an associated decision. He may not give a present at the same value. This act is considered as BRIBERY and CORRUPTION.

A KG employee and Third Party authorized to act on behalf of KG may not offer or make a facilitating payment to a Public Official to ensure or accelerate a routine and compulsory state act. This act is considered as BRIBERY and CORRUPTION.

OUR ANTI-CORRUPTION AND ANTI-BRIBERY POLICY FOR RELATIONS WITH THE THIRD PARTIES AND KG EMPLOYEES

The Third Parties and KG employees may not make or promise a payment or may not give a valuable article, directly or indirectly, to an entity, institution, public official on behalf of KG in order get an illegal, unfair and non-transparent advantage and may not provide business or advantage to their family members even for interests of KG.

KG Employees may not request for commission, gift to a Third Party, job, service, entertainment, various advantages etc. for their family members for commercial business with KG directly or indirectly. This act is considered as BRIBERY and CORRUPTION.

The Third Party may not promise commission, gift to a KG employee, job, service, entertainment, various advantages etc. for their family members for getting commercial advantage directly or indirectly.  This act is considered as BRIBERY and CORRUPTION.

THIRD PARTY EVALUATION CRITERIA OF KG FOR ANTI-CORRUPTION AND ANTI-BRIBERY

  • Does the Third Party have a family or commercial relationship with public and government officials?
  • If the Third Party is a company, is its owner or one of partners a government official? Does this duty offer various advantages to his personality or customers?
  • If the Third Party is a private person, does he perform or has he performed a state function? Does this duty offer various advantages to his personality or customers?
  • How is the reputation of the Third Party in respect of corruption? Has the Third Party been subject to a public investigation or legal proceeding due to bribery or corruption?
  • Does the Third Party accept KG ANTI-CORRUPTION AND ANTI-BRIBERY POLICY and does he has a working method complying with it?
  • What kind of recording system does the Third Party has in respect of his revenues, does he transparent in this respect?
  • Is the fee, claimed by the Third Party in consideration of his services, consistent with the market conditions?

SANCTIONS FOR NON-COMPLIANCE WITH THE ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

KG employees, who fail to comply with the ANTI-CORRUPTION AND ANTI-BRIBERY POLICY OF KG, are punished by work deductions, indemnity, fine and dismissal and similar disciplinary punishments as a result of evaluation by KG Ethical Ethics Board. In addition, legal action is taken against them.

A Third Party, who fail to comply with the ANTI-CORRUPTION AND ANTI-BRIBERY POLICY OF KG, is punished by work deductions, indemnity, fine and termination of employment contract and similar disciplinary punishments as a result of evaluation by KG Ethical Ethics Board. In addition, legal action is taken against them.

AUTHORITY

You may contact with KG ETHICS BOARD for your questions and problems related to our Anti-Corruption and Anti-Bribery Policy.

ETHICS BOARD

The Ethics Board is responsible for investigating and solving complaints and notices regarding violation of the ethical rules in the scope of Keskin Güngör Customs Consultancy Company Business Ethics Rules. The Ethics Board, working as affiliated to the Board of Directors, is composed of the persons on the following positions:

  • Chairman – Zafer Yalçin
  • Member – Recep Esnemez
  • Member – Kerim Dişli

Ethics Board e-mail: etik@kg.com.tr

Ethics Board Address: Şakir Kesebir Cd. Gazi Umurpaşa Sk. Balmumcu Plaza 1 Apt. No: 30 D: 3-5 Balmumcu-Beşiktaş / ISTANBUL

Ethics Board telephone number: +90 212 356 03 45