OPEN DOOR AND ETHICS HOTLINE POLICY

1. PURPOSE

This policy aims to provide all employees within Sabah Yatak San. ve Tic. A.Ş. with a channel where they can safely and confidentially share any unethical behavior, misconduct, or other concerns in the workplace. The open door and ethics hotline practices support our company's corporate culture based on the principles of honesty, accountability, and fairness.

2. SCOPE

This policy applies to all employees, interns, subcontractors, and third-party business partners of Sabah Yatak San. ve Tic. A.Ş.

3. OPEN DOOR POLICY

• Transparent Communication: Employees have the right to share any concerns or suggestions directly with their managers or senior executives.
• Feedback: Managers commit to addressing all reported concerns fairly and impartially, seeking effective solutions.
• Non-Retaliation: No employee who uses the open door policy shall be subjected to discrimination, retaliation, or any adverse treatment as a result.

4. ETHICS HOTLINE POLICY

• Purpose of the Ethics Hotline: The ethics hotline is a communication channel through which employees can report ethical violations, unlawful behaviors, or concerns encountered in the workplace, either anonymously or by providing their names.
• Access to the Ethics Hotline: The ethics hotline can be accessed through the following methods;
  • Phone : (0282) 655 59 76
  • Email: [email protected]
  • Complaint Box: Boxes located at the employee entrance gate.
  • Production Information Forms: Employee complaint/suggestion section included in daily production forms.
• Anonymity: Employees may submit their reports completely anonymously if they wish. The company commits to protecting this right to anonymity.
• Confidentiality: All reports are handled in accordance with confidentiality principles and shared only with relevant personnel.
• Non-Retaliation: Employees who report through the ethics hotline will not be subjected to any retaliation or discrimination.

5. REPORTING PROCESS

• 5.1. Submission: Employees can convey their concerns through the open door policy or the ethics hotline.
• 5.2. Evaluation: Reported issues are reviewed by an independent unit or the designated ethics committee.
• 5.3. Resolution: After necessary investigations, resolution steps are determined and feedback is provided to the relevant party.

6. RESPONSIBILITIES

Managers:

• Encourage employees to confidently use the open door policy and take ethical violations seriously,
• Be objective and transparent,
• Support their employees’ personal development and career planning,
• Avoid making promises they cannot fulfill,
• Foster open discussions with team members,
• Ensure individuals’ identities remain confidential.

Ethics Committee:

• Responsible for impartially investigating and resolving reported issues.

Employees:

• Responsible for acting in accordance with policies and reporting observed misconduct,
• Expected to first attempt to resolve issues through peer (horizontal) communication. We promote a culture of trust and communication in both horizontal and vertical interactions.

7. TRAINING AND AWARENESS

The company regularly provides training to its employees on the open door and ethics hotline policies and conducts awareness activities to enhance the effective implementation of these policies.

8. POLICY REVISION

This policy will be regularly reviewed and updated as necessary in accordance with changing legal regulations or company needs.