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CODES OF ETHICS

The "Codes of Ethics" of Sinpaş Gayrimenkul Yatırım Ortaklığı A.Ş. that is obligatory to be complied with by all managers and employees are defined in order to increase the corporate value of our Company and to add financial value to the shareholders.

The Board of Directors, managers and all employees are expected to comply with the codes of ethics. It is aimed with these codes that the employees of our Company be aware of the institutional effects of their behaviours and attitudes, and to ensure the creation of a transparent, honest and reliable communication environment in any decision and business management process related to our Company, in the ultimate targets set and in the management of the relations with the shareholders as a public company.

SHAREHOLDERS

  • - The main purpose of Sinpaş GYO is to create positive value and to ensure that the investments of the shareholders are managed and valued in the most effective way.
  • - Each shareholder is given the exact same value regardless of the amount of their shares.
  • - The shareholders are guided and informed in accordance with the relevant legislation published by the Capital Markets Board.
  • - In order to enable the shareholders to communicate in a comfortable manner, an environment is prepared for using various communication channels.

ACTIVITY STANDARDS

  • - It is essential that the activities of the Company are carried out in accordance with the principles of transparency, honesty and accuracy.
  • - It is essential to comply with any legal rules and limitations that are associated with the activities of the Company.
  • - The rights and freedoms of the persons, institutions and organisations that are related to the employees and activities are respected.

EMPLOYEES

  • - The employees have to act in accordance with the laws, legislations and internal regulations.
  • - It is ensured that any rights of the employees granted by the laws are protected. It is ensured that the personal rights of every employee are delivered in full, accurately and timely. The necessary ground for a safe and healthy work environment is prepared.
  • - The employees are behaved fairly and it is adopted to provide equal opportunities in equal conditions.
  • - It is unacceptable for any employee to be exposed to psychological harassment such as discrimination, exclusion, intimidation, etc. or to cause such disturbances.
  • - It is not acceptable for any employee to be harassed and disturbed on sexual, social and physical matters to cause such disturbances.
  • - The employees are expected to adopt and protect the name and reputation of Sinpaş GYO.  
  • - The employees are obliged to work in harmony with their co-workers and managers in the workplace, to establish good and humane relations with the private or official persons and organisations within a relationship with the workplace, and to perform their work in an honest and fast manner. In the case of determination of any employee who acts in breach of the principles of business ethics, such situation should be reported to the Management by being documented.
  • - The employees are obliged to protect the benefits of the work and workplace conducted by the Company, and to avoid any kinds of actions that are harmful to such benefit.  In this context, the employees may not use the Company's facilities for personal benefits, engage in any unlawful behaviour and attitude, and they are obliged to submit to the Management the proposals that offer them benefits.
  • - The employees may not accept official or private, permanent or temporary, paid or free of charge duties without being permitted by the organisation, and they may not engage in trade.
  • - The employees are obliged to keep the information and secrets they have learned about their job and organisation, whether or not they are related to their task. The secrets and information learned or the documents related to these may not be given or disclosed to unauthorised persons or authorities. This obligation continues after the termination of the relationship of the employee with the organisation.
  • - The employee is obliged to inform and submit the Human Resources Department in a timely manner regarding any changes in the family, civil and address status and the information related to the personal, family or relatives of the employees in terms of the rights and obligations set out in the agreements and/or regulations and the documents that such information is based on.
  • - The personal information of employees and job applicants is kept secret/protected.
  • - Proposals of each employee are considered as an opportunity to improve the organisation and processes and forwarded to the relevant unit manager.

GIFT EXCHANGE

  • - Gifts that might go beyond the purpose of the gift (which may overshadow the objectivity of the counterparty/have a high value) and that might leave the parties in a difficult position may not be given to the companies/employees who are involved, and such gifts may not be accepted by the employees.

CUSTOMERS - COMPETITORS - SUPPLIERS

  • - It is essential that the relations with the customers and suppliers are carried out on a long-term and trust-based manner and on a professional ground that will have consequences in favour of the Company.
  • - It is taken care of improving the cooperation with the partners that adopt the ethical values of Sinpaş GYO.
  • - No goods or services that may harm and/or mislead the customers may be provided to them.
  • - Establishing contacts with the competitors and making agreements in order to boycott the customers or suppliers is prohibited.
  • - Our company is committed to acting with fair competition principles in its field of activity and other companies carrying on activity in the sector are expected to demonstrate the same sensitivity.
  • - It is prohibited to mention names and make negative statements against the competitors and their managers in the press.
  • - Establishing contacts and making agreements with the competitor companies on issues such as fixing the prices of goods and services and sharing territories/markets/customers is prohibited.
  • - Unethical or unlawful means may not be used to access information about other companies, and the employees are prevented from such practices. However, the use of public information of the companies (web site, price list, advertisement, published text, etc.) is not considered inconvenient.
  • - The information (commercial, personal, etc.) of the suppliers and customers are kept hidden/protected.

PUBLIC DISCLOSURE

  • - No employee may make any verbal or written statement representing the Company, except for the parts as a task assigned.
  • - The information tools included in the Information Policy of the Company are used in such a way that the shareholders and stakeholders can make maximum use of them.
  • - It is ensured that the information that the company is obliged for public disclosure and that is required by the shareholders and stakeholders is provided and updated in an easily accessible and equal manner.

BOARD OF DIRECTORS

  • - The members of the Board of Directors may not submit to the pressures that might give rise to the detriment of the shareholders, accept pecuniary benefits and dissemble any corruption.
  • - The members of the Board of Directors may not disclose any confidential information and commercial secret regarding the company.

SOCIAL RESPONSIBILITY

  • - Sinpaş GYO acts with the awareness of social responsibility in carrying on activity in its sector.
  • - Sinpaş GYO promotes its employees for voluntary contribution to social activities for establishing awareness of social responsibility.
  • - Sinpaş GYO takes maximum care on protecting the environment both in its activities and the activities of its business partners.
  • - Sinpaş GYO uses the natural resources and energy resources efficiently and prevents their wastage.

COMPLIANCE WITH THE RULES

All Sinpaş GYO employees without an exception shall give effort to implement these principles to the fullest. In addition, in the case of determination of any factor in breach of the codes of ethics, the employees are obliged to immediately notify the management. Should any loss of work occur due to complying with these rules, such situation shall not be considered as an adversity.

The Codes Of Ethics are defined, updated and modified by the Corporate Management Committee. The Codes of Ethics are submitted to the information of the General Assembly upon their approval by the Board of Directors, and included in the Company website and annual activity report.