SABAH BEDDING SUPPLIER CODE OF CONDUCT

Behind every activity and project carried out by SABAH YATAK SAN. VE TİC. A.Ş. (hereinafter referred to as SABAH BEDDING) lie corporate values that define the way of doing business, support the corporate culture and vision, and are embraced by every SABAH BEDDING employee;

Our Values

• Trust: We maintain an open relationship with our employees based on mutual trust, respect, and success.
• Commitment: Quality, health, safety, and environmental commitment are among our key objectives.
• Solidarity: We share successes and stand together against failures.
• Inclusiveness: We strive to include our stakeholders in processes and decision-making mechanisms, ensuring no stakeholder is excluded due to discrimination or prejudice.
• Integrity: We strictly adhere to relevant laws, regulations, and internationally accepted ethical values in all our activities.
• Innovation: Excellence, innovation, and continuous improvement are among our primary goals.
• Responsible Management: Fully aware of our responsibility to manage all stages of our activities, we fulfill all obligations related to society, environment, and economic issues throughout the service life.
• Sustainability: We embrace a corporate sustainability approach aware of economic, environmental, and social responsibilities toward internal and external stakeholders.
• Transparency: We commit to an open attitude regarding decisions and activities affecting the environment, society, and economy, and ensure honest and clear communication with stakeholders.

1. INTRODUCTION

SABAH BEDDING is committed to creating a sustainable future while carrying out its global projects and conducting its business in accordance with the highest ethical and compliance standards. SABAH BEDDING is a signatory to the United Nations Global Compact and has pledged to adhere to the 10 principles defined within this framework. SABAH BEDDING aims to extend this commitment throughout its entire value chain. Accordingly, it expects the same sensitivity and care from all its suppliers, subcontractors, consultants, service providers, representatives, and all other business partners (collectively referred to as “Suppliers”).

SABAH BEDDING expects all its suppliers to comply with the ten principles of the United Nations Global Compact, the sections of the United Nations Universal Declaration of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work relevant to the business world. In this regard, SABAH BEDDING requires all suppliers to adhere to the rules outlined in the Supplier Code of Conduct.

All suppliers entering into business relations with SABAH BEDDING and its affiliates are responsible for ensuring that their companies, employees, suppliers, and subcontractors understand and comply with these rules.

2. SUPPLIER CODE OF CONDUCT

SABAH BEDDING suppliers commit to ensuring that they, their employees, subcontractors, and suppliers comply with the rules outlined below.

2.1. Compliance with Laws

SABAH BEDDING suppliers are responsible for being aware of, complying with, and fully adhering to all applicable national and international laws, regulations, and other official requirements related to themselves and their operations, as well as to the contractual obligations agreed upon with SABAH BEDDING.

2.2. Compliance with Policies and Procedures

SABAH BEDDİNG suppliers are obliged to comply with all corporate and project-related policies, procedures, and plans relevant to their work, including but not limited to SABAH’s sustainability, occupational health and safety, environmental (HSE), quality, and information security policies.

2.3. Human Rights and Employee Rights

SABAH BEDDİNG conducts all of its operations in accordance with human rights and expects the same diligence from all its business partners. SABAH BEDDİNG does not tolerate any human rights violations during its activities. Accordingly, SABAH BEDDİNG requires all its suppliers to:

• Not employ child labor and comply with all regulations set by the International Labour Organization regarding the employment of young workers,
• Avoid all forms of labor practices that violate human rights, including but not limited to forced or compulsory labor, unregistered employment, bonded labor, abuse, physical punishment, all forms of modern slavery, and human trafficking,
• Refrain from subjecting employees to any form of discrimination (such as race, religion, language, color, gender, sexual orientation, disability status, etc.),
• Not engage in or allow any form of corporal punishment; mental, physical, sexual, or verbal harassment; harsh or degrading disciplinary actions; or mistreatment,
• Not pay wages below the legally mandated minimum wage and to ensure a fair wage scale in comparison to the prevailing industry average,
• Comply with the labor laws and employee rights regulations in the country in which they operate,
• Respect employees' rights to form or join independent trade unions and to engage in collective bargaining.

2.4. Health and Safety of Employees

Suppliers are obliged to provide their employees with a working environment where all necessary measures related to occupational health and safety—and where applicable, nuclear safety—are taken. In this context, they must take all necessary precautions and provide the required equipment in full. All suppliers must fully comply with the occupational health and safety and nuclear safety procedures established at SABAH BEDDİNG’s and its affiliates’ facilities and construction sites, and must take and follow all necessary measures to prevent any accidents. Accordingly, suppliers must:

• Train their employees on HSE (Health, Safety, and Environment) matters and supervise them under all conditions and circumstances,
• Make maximum effort to contribute to SABAH BEDDİNG’s HSE and zero-accident goals,
• Ensure uninterrupted access for their employees to clean water, food, and health services,
• Halt work and inform the relevant OHS (Occupational Health and Safety) unit in case of any situation that may pose a danger to employees or the environment,
• Provide a safe working environment for their employees and take all necessary safety precautions in this regard.

2.5. Management of Environmental and Social Impacts

SABAH BEDDİNG expects all its suppliers to comply with the applicable laws and regulations, as well as relevant international standards, regarding environmental protection and the socially responsible conduct of operations. Accordingly, suppliers must:

• Take all necessary precautions to avoid harming the environment,
• Obtain and maintain all required environmental and social permits, approvals, or licenses necessary for their operations,
• Fulfill their responsibilities arising from SABAH BEDDİNG’s related plans and procedures completely,
• Assess the environmental and social impacts of the work undertaken and define targets and actions to reduce them,
• Strive to reduce the use of natural resources and pollution,
• Take actions to reduce their carbon and water footprint,
• Prefer environmentally friendly and sustainable practices wherever possible; and provide relevant certification schemes (e.g., FSC, MSC) or eco-labels (e.g., ECO Label),
• Have an environmental management system that prioritizes the protection of wildlife, plants, and endangered species,
• Identify potential human rights risks to local communities caused by their activities, take necessary precautions to prevent violations, establish communication channels for reporting potential violations, and show due diligence in resolving such reports,
• Operate in accordance with zero waste principles and obtain a zero waste certificate.

2.6. Honest and Ethical Business Practices

SABAH BEDDİNG operates in accordance with the legal requirements of the countries in which it operates, guided by a responsible management approach, and maintains this legal compliance through a robust Ethics and Compliance program. Within the scope of this program, SABAH BEDDİNG expects its suppliers to ensure the same level of legal compliance and to take the necessary measures to maintain it.

2.7. Anti-Bribery and Anti-Corruption

SABAH BEDDİNG strictly prohibits all forms of bribery and corruption in its operations. SABAH BEDDİNG suppliers must not offer, give, receive, or solicit bribes, and must avoid any behavior that may raise suspicion of corruption, including facilitation payments. They must ensure that all payments made or gifts given are in full compliance with applicable laws. SABAH BEDDİNG expects all suppliers to maintain proper records and documentation of all payments and to establish internal control mechanisms to prevent bribery and corruption within their organizations.

2.8. Prevention of Anti-Competitive Behavior

SABAH BEDDİNG promotes fair and robust competition in its operations and maintains transparent communication with public authorities in the countries where it operates, in full compliance with the fair competition laws of those countries. In this context, SABAH BEDDİNG suppliers must:

• Act in accordance with the relevant competition laws of the countries in which they operate,
• Avoid entering into inappropriate agreements or any interactions with competitors that may create a misleading impression,
• Refrain from abusing their market position and from engaging in behaviors that could negatively impact competition, such as price-fixing or bid-rigging.

2.9. Prevention of Conflicts of Interest

SABAH BEDDİNG expects its suppliers to take the necessary measures to prevent conflicts of interest. Accordingly, suppliers must:

• Ensure that their employees make business decisions during their work based on the interests of the company, not personal gain,
• Avoid and take precautions against situations that may result in or give the appearance of a conflict of interest,
• Inform SABAH BEDDİNG in case any personal interest arises from the business relationship,
• Prevent their employees from using their positions to offer gifts, invitations, or other benefits to SABAH BEDDİNG employees or third parties. This rule does not apply to symbolic gifts or hospitality that are lawful and comply with SABAH BEDDİNG's Code of Conduct.

2.10. Trade Controls

SABAH BEDDİNG suppliers must ensure that all their transactions comply with the conditions of all applicable export licenses and regulations. Suppliers who transport and/or use products subject to export and import controls or sanctions are responsible for understanding and adhering to the relevant laws, regulations, and company rules. Suppliers must stay informed about and comply with frequently changing sanctions, export restrictions, economic sanctions, boycott laws, and embargo regulations.

2.11. Protection of Personal Data and Confidentiality

All suppliers must ensure that any personal data shared with them by SABAH BEDDİNG due to the business relationship is processed and stored in compliance with the law, that necessary security measures are taken, and that they act in accordance with the principles, rules, and procedures set forth in all applicable data privacy legislation. Suppliers are required to accept and commit to specific contractual obligations regarding the protection of personal data in the agreements to be made with SABAH BEDDİNG.

2.12. Information Security

If SABAH BEDDİNG suppliers have access to any confidential information belonging to SABAH BEDDİNG, they must remain vigilant and take necessary precautions in advance to protect such private and confidential information both during and outside the course of business. It is strictly prohibited for suppliers to use SABAH BEDDİNG’s confidential information for their own benefit or for the benefit of any third parties.

2.13. Media and Social Media

Suppliers are expected not to make any positive or negative comments or share any information or documents related to or attributable to SABAH BEDDİNG through media channels or on social media. Suppliers must not share any confidential or strategic information, documents, or visuals—including trade secrets of SABAH BEDDİNG—on personal social media or network accounts. They must refrain from making statements or adopting attitudes that could discredit SABAH BEDDİNG’s services, clients, suppliers, or competitors. Suppliers must not respond to media or third-party inquiries about SABAH BEDDİNG or make any comments on behalf of the company. Before making any public statements regarding their work with SABAH BEDDİNG or its affiliates, suppliers must consult with the Corporate Communications Department and obtain written approval.

3. PROCEDURE IN CASE OF BREACH OF THE RULES

SABAH BEDDİNG requires all suppliers to understand and act in accordance with the Supplier Code of Conduct. SABAH BEDDİNG reserves the right to periodically request information and documentation from suppliers and to conduct on-site or remote audits to verify their compliance with these rules. Suppliers acknowledge and accept these rights of SABAH BEDDİNG.

In the event of a suspected or confirmed violation, or upon receiving a valid report, SABAH BEDDİNG may request information and documentation from the supplier to monitor compliance with the rules outlined in this document and may carry out audits with or without prior notice. Suppliers are required to submit all relevant documents requested by SABAH BEDDİNG within 2 days at the latest.

Suppliers are obligated to report to SABAH BEDDİNG if they witness, know of, or suspect any violation of the rules. Reporting a concern, violation, or potential violation gives SABAH BEDDİNG the opportunity to detect and prevent the issue at an early stage.

In the event of a violation of the rules stated in this document, the supplier must have in place a fair, non-retaliatory grievance procedure that its employees and subcontractors can use. Suppliers may report any suspected violations or issues regarding SABAH BEDDİNG or its affiliates through the SABAH BEDDİNG Ethics Line or email address, or by contacting the Supply Chain Management Department or the Corporate Sustainability and Compliance Department.

SABAH BEDDİNG maintains a strict zero-tolerance policy for retaliation. Retaliating against supplier employees who report concerns, request support in cases of ethical dilemmas, cooperate in investigations, or refuse to engage in suspicious or improper activities is strictly prohibited.

It is the supplier’s sole responsibility to comply with the Supplier Code of Conduct. In addition to this commitment, suppliers are also expected to ensure that the same commitment is upheld by their own subcontractors and lower-tier suppliers.

If any non-compliance is identified during audits, SABAH BEDDİNG reserves the right to unilaterally terminate its business relationship with any supplier that knowingly violates the behaviors specified in the Supplier Code of Conduct. Furthermore, SABAH BEDDİNG may require suppliers to implement a corrective action plan and may conduct follow-up audits to ensure that the planned measures are effectively carried out.

SABAH BEDDİNG may request the removal of any supplier employee who engages in conduct that is illegal or contrary to the Code of Conduct or may cease working with the supplier. Violations of SABAH BEDDİNG’s policies—particularly concerning human rights, anti-bribery and corruption, or any part of the Supplier Code of Conduct—by any unit of the supplier or its subcontractors may result in the termination of the contracts made with the supplier.