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Turkcell Common Values and
Code of Business Ethics

TODİEK

Turkcell Common Values

Code of Business Ethics

We Respect Fundamental Rights and Freedoms

We Respect Fundamental Rights and Freedoms

As Turkcell and Turkcell Group Companies, we act in conformity with the policies put into effect in order to protect the fundamental rights and freedoms of our employees specified in international declarations/conventions regarding the fundamental rights and freedoms, to which Turkey is a signatory/ratified party as well as in the Constitution of the Republic of Turkey and to enable our employees exercise these rights and freedoms in accordance with the principles laid down in applicable international and national legislation.  We take the necessary measures and fulfills the legal obligations for the protection of personal data in accordance with the applicable legislation.

The employees of Turkcell and Turkcell Group Companies have the right to apply to the Human Resources Business Partner or the Ethics Committee through Ethical Notification Channels for alleged violations of their fundamental rights and freedoms.

We Care About Personal Data Protection and Privacy

We Care About Personal Data Protection and Privacy

  • As Turkcell and Turkcell Group Companies, we are committed to respect the privacy of the personal data of our employees/subscribers/users.
  • We process personal data; in accordance with the law, only for appropriate business purposes, and to a limited extent for this purpose.
  • We do not share, save, transfer and process personal data with unauthorized persons, except the reasons for data processing specified in the Law on Protection of Personal Data or having express consent of the data subject.
We Show Extra Sensitivity About Employee/ Subscriber/ User Information

We Show Extra Sensitivity About Employee / Subscriber / User Information

As Turkcell and Turkcell Group Companies, we are committed to respect the privacy of the personal data of our employees/ subscribers/ users. Such data is obtained only if it is necessary for the activities of Turkcell and Turkcell Group Companies and in conformity with the applicable legal regulations and is retained for the legal periods as maximum.

If any personnel is authorized to have access to the personal data of employees / subscribers / users of Turkcell and Turkcell Group Companies by virtue of his/her duty, he/she is deemed to have accepted the obligations determined within the company in advance. He/she knows that a contrary attitude may violate the rules of the Company, as well as lead to criminal and civil liability both for himself/herself and the Company, in accordance with the legislation on the Protection of Personal Data.

We Do Not Excuse Harassment and Psychological Violence (Mobbing)

We Do Not Excuse Harassment, Psychological Violence and Mobbing

As Turkcell and Turkcell Group Companies, we do not tolerate or excuse any employee who committing harassment, sexual harassment, mobbing and discrimination.

We Act Under Certain Rules for Invitations and Travels

We Act Under Certain Rules for Invitations and Travels

We comply with company regulations regarding bribery and corruption when we join various organizations and invitations from our business partners like customers, dealers, distributors, suppliers, banks etc.

We Pay Attention When Receiving and Giving Gifts

We Pay Attention When Receiving and Giving Gifts

As a matter of course, we do not expect anything in return and do not secure any advantage other than payments in accordance with company procedures in our relations with our stakeholders.

Social Responsibility Projects

Social Responsibility

As Turkcell, we have been fulfilling our responsibility towards the society by way of the projects we have supported in different areas such as education, culture, art, sports and environment since the very first day we have been established.

We cover life with our technology, and we work to reduce inequalities in line with the United Nations Sustainable Development Goals. With the equalizing power of technology, we offer equal access to information for children, women, refugees, the disabled, the elderly and the low-income people, without leaving anyone behind, and we inspire in this direction.

At the basis of our social responsibility approach is our responsibility to our shareholders, employees, customers, dealers, non-governmental organizations, universities and the social partners formed by the media.

Environment, Health and Safety

As Turkcell, we being sensitive to local and global environmental problems, our responsibilities towards and influence areas in the environment are evaluated in all business processes and operations are managed according to these priorities with the aim of leading also for the environmental awareness just like in the field of technology.

The employees of Turkcell and Turkcell Group Companies are obliged to act in accordance with laws and policies imposed for environment, health and safety issues. Turkcell Environmental Policy is adopted and supported with the awareness of sustainability and all resources are used economically in business environments and related places.

Environment, Health and Safety
Responsibilities of the Management Team

Responsibilities of the Management Team

Our Management Team (Turkcell Board of Directors; Turkcell General Manager and the Executive Vice Presidents of Turkcell) declare to act honestly and reliably by evaluating the conflicts of interest arising or may arise between their personal relationships, financial or commercial interests and their responsibilities to Turkcell ethically.

Our Management Team make full, fair, accurate, timely and understandable disclosures in all reports and documents disclosed to the public or submitted to the capital markets regulators with which the Company is registered and act in accordance with all of the laws, regulations and rules that Turkcell is bound to.

Our Management Team ensure compliance with not only the wording but also the spirit of these ethical rules and strive to create a business culture in compliance with the laws and Turkcell policies in all of the activities of Turkcell.

We Conduct Our Activities in Compliance with Competition Law Rules

We Conduct Our Activities in Compliance with Competition Law Rules

  • We take various measures for carrying out all of our businesses and transactions in accordance with the applicable legislation in order to maintain effective competition in the markets in which we operate.
  • We ensure that all our employees review the guidelines, information and trainings prepared to work in accordance with the objectives and basic principles of competition law.
  • In line with our general principles, the written or verbal practices between the Competitors which will result in the restriction of competition; complicating the activities of competitor entity; preventing new entrant entities; applying high sales prices and sales prices less than cost are avoided.
  • The resale prices of third companies reselling Turkcell products and services are not interfered with.
  • We carry out our activities in the markets in which we operate in conformity with the competition rules regulated under, the Turkish Commercial Code, the Law on the Protection of Competition, the Electronic Communication Law and secondary legislation.
Information Security Rules and Confidentiality

Information Security Rules and Confidentiality

Information security policies intends to ensure the effective management of information security policies as well as the security against risks, accuracy and continuous use of information assets in all services and service management activities by operating the information security management system established with the approval of senior management to manage information security needs of Turkcell.

It is important that all employees configure their own business processes in accordance with these policies. Therefore they, as users and owners of information assets, are responsible for the information assets, business secrets and the application of the rules written in the policies in the basic business processes.

Protection of Company Assets

Protection of Company Assets

The employees of Turkcell and Turkcell Group Companies are obliged to protect the company assets against loss, damage, theft, unauthorized access, use for purposes other than business, use of personal interest and misuse. The company assets cannot be used to create and share content violating the business principles of Turkcell, which will disturb others. All Turkcell assets should be used only for legitimate business purposes.

Information is one of the most critical asset categories. Employees should maintain the confidentiality of information entrusted to them by Turkcell or customers of Turkcell. All employees are required to comply with "Turkcell Information Security and Disclosure" policies and procedures, which is published in Turkcell's internal intranet pages.

Priority of Company’s Interests

Priority of Company’s Interests

The employees of Turkcell and Turkcell Group Companies fulfill their responsibilities independently of their personal interests, by considering the priorities of the company and avoid actions, relations and situations in which their personal interests conflict or appear to conflict with Turkcell's interests. Employees are prohibited from taking for themselves personally opportunities that are properly within the scope of Turkcell's activities, using corporate property, information or position for personal gain, and competing with Turkcell.

Conflict of interest exists when a person's private interest interferes in any way, or even appears to interfere, with the interests of Turkcell. A conflict situation can arise when an employee takes actions or has interests that may make it difficult to perform his or her work for Turkcell objectively and effectively. Conflicts of interest also arise when an employee or a member of his or her family, receives improper personal benefits as result of his or her position in Turkcell.

Books and Records Accuracy and Compliance with Legal Requirements

Books and Records Accuracy and Compliance with Legal Requirements

  • Turkcell has established internal control standards and procedures to ensure that its assets are protected, appropriately used and that financial records and reports are accurate and reliable. Turkcell and Turkcell Group Companies Employees have a common responsibility to maintain and comply with necessary internal controls and may be held accountable when necessary. They ensure that all transactions are recorded in the relevant accounts and periods, available in the current documentation, and verifiable in the prescribed detail. They are obliged to preserve the records for the appropriate time period stipulated in the Turkcell and Turkcell Group Companies procedures and the law.
  • They shall cooperate with the authorities by providing required information and documents in all internal and external audits & inquiries.
  • They are obliged to comply with both the FCPA (Foreign Corrupt Practices Act) and the local laws when working with public institutions.

Turkcell Ethics Notification Channels

Turkcell Ethics Notification Channels are established for Turkcell employees, business partners, suppliers, Turkcell stores, shareholders and Turkcell customers to send Ethic Committee; issues related to Turkcell employees and institutional practices that are inappropriate to the Turkcell Ethic Rules.

Applicants are not required to share their personal information. However, if they share their personal information, the notification will be evaluated under the rules of confidentiality. In applications which contact information is shared; applicants are informed about the result of the evaluation of Ethic Committee.

Turkcell Ethics Notification Channels should be used only for the issues that are thought to be inappropriate of Turkcell Business Ethics Rules. Consumer complaints, suggestions, objections, etc. should be send via other contact channells (Service and Customer Complaints Departments) of Turkcell.

Turkcell Ethics Notification Channels
Notification Channels
E-mail: etikbildirim@turkcell.com.tr
Address: Turkcell İletişim Hizmetleri A.Ş. Ethics Committee Aydınevler Mah. İnönü Cad. No:20, Küçükyalı / İstanbul