OUR COMPANY POLICIES
KAPLANLAR ETHICS CODE
Comply with laws and regulations
We will comply with both the letter and the spirit of the laws and regulations that govern our business. We will all
• be honest, open and cooperative with all regulators;
properly record, report and review financial and tax information; and
comply with all employment legislation affecting our businesses in countries in which we operate.
Zero tolerance towards discrimination and harassment
We are committed to providing a safe and respectful working environment free from threats, violence, harassment and discrimination. We will all
• treat employees fairly and impartially throughout every stage of their work at Kaplanlar including recruitment, progression, terms and conditions and representation;
• not tolerate harassment or discrimination of any kind;
• treat each other, suppliers and customers with dignity and respect; and
• establish a consultative structure allowing everyone to have their say.
A safe and healthy working environment
We are committed to providing a safe and healthy working environment. We will all
• comply with all environmental, health and safety laws and regulations;
• provide and wear the appropriate equipment;
• assess and control the specific risks arising from our work activities;
• report accidents or injuries or safety concerns to the appropriate manager in the business;
• not accept the use of alcohol or illegal drugs or abuse legal drugs in the workplace;
• safeguard the health and safety of visitors, contractors and any others that may be affected by our operations; and provide appropriate health and safety and emergency training for all employees.
Our health and safety policy
Limit our environmental impact
We observe environmentally-sound business practices because it is the right thing to do. Kaplanlar will work to promote environmental care and awareness, with an emphasis on the need to reduce energy consumption and waste production. We will all
• comply with environmental laws and regulations; and
• report environmental concerns to the appropriate manager.
Our environmental policy
Strictly adhere to competition laws
We value open and fair competition and will not knowingly enter into business arrangements that eliminate or discourage competition or that provide us an improper competitive advantage. It is our policy to compete independently and not to enter into any anti-competitive agreements. We will all
• familiarise ourselves with and adhere to all laws that apply to our areas of the business;
• not price fix, offer bribery or kickbacks, enter into agreements with competitors to divide the markets in which we compete by allocating territories or markets and/or limiting the production or sale of products or product lines, or condition the sale of one product on the sale of another unwanted product or service.
Comply with anti-bribery and corruption legislation
We will not voluntarily give or receive (either directly or through a third party) any financial payment or other advantage, with the intention to induce or reward any person to improperly perform a function or activity that he is
otherwise expected to perform in good faith, impartially or from a position of trust.
We prohibit bribery and facilitation payments in any form whatsoever, whether to public officials or business contacts or made by Kaplanlar companies or on their behalf. We compete on the merits of our products and services and do not use the exchange of business courtesies to gain an unfair competitive advantage, nor do we offer or accept gifts of substance or inducements, particularly those that encourage or reward decisions in the course of business. If in doubt, please seek clarification from your immediate supervisor.
We will all act honestly and with integrity to safeguard the resources for which we are responsible.
These are defined as a gift, gratuity, favour or other intangible or tangible item having monetary value for which fair market value is not paid by the recipient.
These include, but are not limited to cash, entertainment and recreation (tickets to sporting, recreational or other events), transportation, discounts, lodging.
Business courtesies exclude advertising or promotional items of little intrinsic value (generally $20 or less) such as a coffee mug, modest refreshments and other items, apart from transportation with a value of less than $20 per occasion.
Employees who procure goods or services will
• treat all suppliers uniformly and fairly and avoid favouritism.
• not accept gifts from suppliers or vendors except advertising or promotional items.
Employees in non-procurement functions can accept business courtesies as long as
• the provision or acceptance will promote goodwill and successful business relations;
• the courtesies are not lavish or extravagant under the circumstances;
• the courtesies are not frequent and do not reflect a pattern or the appearance of a pattern of frequently providing or acceptance of courtesies from the same entities or persons.
Avoid conflicts of interest
Our business is committed to upholding the highest standards of ethical business conduct and expects the same of employees. It is our policy to ensure employees are precluded from having personal interests in companies which have a business relationship with Kaplanlar and may therefore create a conflict of interest.
Protect sensitive and personal information
We will not use information received in the course of business improperly for personal gain or for any purpose except that for which it was given. We prohibit employees from soliciting and using confidential information from other organisations.
Proper use of company assets
Business resources and assets (physical assets and company information) belong to our shareholders and we will not use them to support a personal business or for an illegal act or purpose which would cause embarrassment to Kaplanlar. We will all
• use and maintain company property, electronic communication systems, information resources, materials, facilities and equipment with the utmost care and respect; and
• use company assets, including cash, for Kaplanlar business only.