Dear Colleagues and Distinguished Stakeholders,

As DIAS Corporate Group, as we continue our steady growth in line with the strength we gain from our employees, we focus on creating value for society and act with the aim of setting an example for our country and the world. Owing to our understanding of sustainability, which is at the core of our group culture, we carry out our activities within the framework of trust-oriented and long-term collaborations with all our stakeholders who are committed to ethical values, by considering environmental, social and corporate governance elements in our activities.

As DIAS Corporate Group, we benefit both the society and the environment with the products and projects we develop in line with our software and technology-oriented activities and the strength we derive from our innovative approach aiming to catch up with global competition conditions as we do so. We strongly adopt the corporate governance approach that embraces the principles of being “Fair”, “Transparent”, “Accountable” and “Responsible to All Related Parties” as a part of our corporate culture, and we sincerely believe in the necessity of ethical behaviour in business life with the effort to take strong steps towards the future. Our ethical values are determined and shared with you, our valuable stakeholders, in order to manage the risks that may arise in this regard.

We therefore expect all employees of DIAS Corporate Group and all our business partners and stakeholders with whom we have commercial business relations to be in compliance with the Ethical Principles Policy and to be sensitive enough to fulfil their responsibilities. DIAS Corporate Group thanks all our stakeholders for their efforts and co-operation for the implementation of the Ethical Principles Policy. 

Sincerely, 

 

Board of Directors of DIAS Corporate Group 

 

1. GOAL and SCOPE 

The purpose of this policy is to determine the framework of the basic ethical rules that all employees, business partners and all stakeholders with whom DIAS Corporate Group interact must comply with, and to guide them in their decision-making and behaviour by taking into account the values that form the basis of individual and social relations while fulfilling their responsibilities.

2. OUR ETHICAL PRINCIPLES AND VALUES 

As DIAS Corporate Group, we hereby expect all third parties with whom we have business relations, including our employees, strategic partners and employers, customers, suppliers and other stakeholders in this context, to ensure that they fully understand and adopt this policy during their operations and activities. In this context, we intend to work with our stakeholders with whom we meet at a common point.

2.1. Diversity and Equal Opportunity

Diversity is whatever makes our employees unique as individuals, including, but not limited to, age, gender, race, colour, marital status, religion, nationality, political beliefs, economic class status, disability and sexual orientation. Diversity enriches our group by providing different viewpoints, fostering innovation and providing the best possible services and solutions for our stakeholders.

We provide equal opportunities to all DIAS Corporate Group employees on the basis of respect for human rights, honesty and fairness. By adopting internationally recognised human rights principles, we are never a party to human rights violations.

2.2. Suitable Working Conditions

All of our stakeholders are entitled to fair, reliable, transparent and peaceful working conditions, and we abide by all applicable laws and regulations.

Child labour and/or any form of forced labour are strictly prohibited.

We abide by the Labour Law, Turkish Penal Code and other laws and regulations regarding working conditions, including working hours, wages and other working conditions.

We endeavour for the professional and individual development of our employees, support them in volunteering for appropriate social and community activities in which they will take part with a sense of social responsibility, as well as observing the balance between business life and private life.

2.3. Dealing With Mobbing 

As DIAS Corporate Group, we refrain from any practice that is defined as intimidating employees by causing discomfort through psychological violence, pressure, siege and harassment, which is considered a criminal offence in the Turkish Penal Code and Labour Law and can be regarded as mobbing. Harassment of any kind, including inappropriate, unpleasant behaviour, mobbing and sexual harassment, such as expressions, gestures or actions that may disturb or humiliate another person, against all our stakeholders and by our stakeholders, is never tolerated.

2.4. Dealing With Bribery and Corruption

As DIAS Corporate Group, we oppose all kinds of illegal, unregistered and counterfeit-oriented factors that pose risks to consumer health, trigger unregistered economy, unfair profit and competition, and lead to tax loss and loss of welfare on a national and global scale.

We never accept taking or giving bribes, regardless of their purpose. Employees of DIAS Corporate Group shall not provide and/or promise material or non-material benefits to third parties, directly or through intermediaries, in order to obtain any benefit. Such offers made to them by third parties should never be accepted, and even if there is no bribery and corruption, they should avoid actions that may be interpreted in this way. We never establish a business relationship with third parties who attempt to work with our group through bribery and corruption.

Under no circumstances will we hold responsible any employee who refuses to engage in any form of improper activity, or who refuses to give or receive a bribe, resulting in loss of business.

2.5. Dealing With Money Laundering 

As DIAS Corporate Group, we adopt a determined approach against money laundering or any kind of illegal activities. No business relationship is established with any third party that may in any way involve our Group in money laundering activities. Each employee is obliged to show due diligence in the combating of money laundering. To this end, our employees are obliged to abide by all applicable laws, regulations and policies of DİAS Group of Companies. As DIAS Corporate Group, we are responsible for supporting efforts to combat money laundering and prevent money laundering activities.

2.6. Data Privacy and Security

We are aware that all kinds of confidential information that are not disclosed to the public, such as trade secrets, marketing, service and business plans, tender information, customer information, personnel information, project drafts, designs, technical data, financial data, production data, product information, system and programme information, procurement information, etc. are within the scope of data privacy and security. As DIAS Corporate Group, we protect the confidential information of our employees and all third parties with whom we have a business relationship in accordance with our policies, procedures and relevant legislation. For protection of confidential information, we use appropriate technologies for record management of data and take the necessary information processing security measures. All third parties with whom we have a business relationship are expected to show the same sensitivity regarding confidentiality and information security.

No privileged information about our employees’ previous employment or other information that may create a risk of unfair competition violations is shared. We also honour confidentiality obligations even after an employee’s employment with our group has terminated. Confidential information of our employees should be used only for the specified purposes and as part of their duties in our group, protect all confidential information/documents they access while performing their work, and abstain from responding to any requests for confidential information requested by third parties regarding the activities of the company. Our employees are committed to comply with corporate confidentiality rules. Employees are constantly informed and instructed on how to actively refrain from activities that may jeopardise confidentiality.

When using all kinds of data relating to an identified or identifiable natural person in our personal data activities, we abide by the Law No. 6698 on the Protection of Personal Data.

In terms of ensuring data confidentiality, we support not only the work required by law, but also corporate ethical behaviour.

2.7. Legal Responsibility and Awareness of Duty

We are committed to act in accordance with the international conventions and standards to which we are a party and all applicable legislation in the sector in which we are active.

We recognise all consequences of violations of laws and regulations. As DIAS Corporate Group, we are fully aware that violations of the Ethical Principles Policy may threaten the general interests of individuals, companies and society and may lead to injustice, material and moral damages which is why it is our duty to inform the competent authorities in order to prevent such situations.

While performing their duties within the limits of the authority given to them, we ask our employees to inform their managers about the issues that go beyond their authority. Acting in accordance with the principles of business ethics in all work done without using working time for personal benefit and not engaging in behaviours that prevent other employees from performing their work properly in this context is the main responsibility of all employees in DIAS Corporate Group.

2.8. Quality, Environment, Occupational Health and Safety

As DIAS Corporate Group, we carry out our activities with innovation-oriented superior quality in the field of software and technology, primarily in the area of marking and tracking solutions. At the core of our activities, we are committed to excellence in all our processes to provide world-class products and services to our stakeholders.

As DIAS Corporate Group, we adopt integrated management system standards in order to ensure the prevention of environmental damage and health threats in accordance with the management approach, risks and environmental impacts of our activities with targets in the fields of Quality, Environment, Occupational Health and Safety. By fulfilling the requirements of Quality, Environment, Occupational Health and Safety Management Systems standards in order to realise these objectives, it is one of our basic policies to increase the satisfaction of our customers and employees. Within the DIAS Corporate Group, all our co-workers are responsible for adhering to these standards.

As DIAS Corporate Group, we adopt Quality, Environment, Occupational Health and Safety, environmental and social sustainability as the basis of our corporate culture with sustainable practices that underlie all the work we perform. By abiding by all applicable environmental laws and regulations, we endeavour to use natural resources efficiently and work towards the development of environmentally and nature-friendly technologies.

We ensure that our stakeholders work so as not to endanger the health and safety of themselves or others. We endeavour to take precautions against occupational accidents and foster a safe working environment for employees. All DIAS Corporate Group employees abide by the rules and instructions set out with this purpose and take the necessary precautions.

2.9. Political Contribution and Relationship Control

As DIAS Corporate Group, we conduct no support activities for political parties, politicians or political candidates, and we do not make donations to these individuals and organisations. We keep an equal distance to all political parties without any expectation of benefit, as we carry out our activities with this sense of responsibility. Accordingly, employees of DIAS Corporate Group are not tolerated to be involved in demonstrations, propaganda and similar activities during working hours and within the boundaries of their workplaces as we never assign our company resources such as vehicles, computers and e-mails to political activities. 

2.10. Dealing With Prevention of Conflict of Interest and Unfair Competition

DIAS Corporate Group employees may not make any transactions in benefit of their spouses, third-degree relatives or themselves, nor may they disclose company trade secrets. All employees of DIAS Corporate Group are strongly expected to immediately inform their managers in the event that they suspect a potential conflict of interest.

Establishing a company or becoming a partner in another company after leaving his/her position in DIAS Corporate Group and doing business with our Group as a seller, contractor, consultant or in similar ways is a very significant point to be aware of that may create negative perceptions. Having an employee who resigned from our Group in a position of decision-making on behalf of our Group in another company is also a point that should be taken into consideration. In the event of such a situation, in order to abide by moral and ethical rules and to prevent conflicts of interest before and after the process, the relevant manager should prepare a report indicating that there is no inappropriate situation and inform the DIAS Corporate Group Ethics Committee, or in the case of an inappropriate situation, no commercial relationship should be established with the relevant person and/or the relevant company.

As DIAS Corporate Group, we comply with all legislation (laws, bylaws, regulations, etc.) and decisions of competent authorities regarding the protection of competition, and we refrain from making agreements or collaborations that may cause unfair competition. Against our competitors and their executives in the press, we do not make negative statements by referring to them by name. Regarding access to information about other companies, we never resort to unethical or illegal means as well as not accepttin DIAS Corporate Group employees to resort to such means.

As DIAS Corporate Group, we utilize all information we obtain as a result of commercial relations in accordance with the Unfair Competition Law, Intellectual Property Law, Turkish Commercial Code and other relevant legislation provisions.

Therefore, we compete effectively only within the scope of legal and ethical areas and refrain from unfair competition. Similarly, avoid making agreements or collaborations that may lead to unfair competition.

2.11. Gifts and Hospitality

As DIAS Corporate Group, we have adopted and rigorously applied principles regarding not giving and receiving gifts, as in many other matters.

Aside from the gifts and hospitality offered in human resources management in accordance with company procedures, no part of the group or employees may give gifts or provide hospitality to other employees or their families on behalf of DIAS Corporate Group.

Receiving and giving gifts in money and monetizable gifts from suppliers, customers or all other third parties that may affect their impartiality and decisions, violate the independent thinking environment, create the impression of the existence of an irregularity, cause or be perceived as causing a dependency relationship is not permitted.

2.12. Social Responsibility, Donations and Sponsorships 

DIAS Corporate Group deems it a duty to be sensitive to the issues that concern the society, to take part in transparent and accountable social responsibility projects in order to support efforts contributing to economic and social development, and we voluntarily carry out activities for a better society and a better environment. We conduct visible and accountable sponsorship and social responsibility activities that do not damage the reputation of our Group. Membership and participation in the activities of any public, institutions and organizations and non-governmental organizations representing our company may be carried out with the knowledge of our management.

Charitable contributions, including, but not limited to, secret payments and benefits, which may damage the reputation of the company, are not allowed.

3. EXPECTATIONS FROM STAKEHOLDERS

The purpose of this policy is to support all our stakeholders, primarily our employees, in making decisions with the right course of action. In this direction, we expect all our stakeholders, with whom we create value, to strictly abide by the DIAS Corporate Group Ethical Principles Policy and utilize it as a guide in their daily work. Sanctions are imposed in case of any violation.

Each stakeholder is responsible for not remaining voiceless when they observe or have concerns about a violation of the DIAS Corporate Group Ethical Principles Policy. Employees and other stakeholders who remain voiceless in such situations might be held liable for failing to report the violation or raise concerns.

Employees are expected to handle all our Group assets responsibly. Assets must be protected from harm and we must avoid using assets inappropriately. We exercise the same care for the assets of any third party we do business with.

Our Group is responsible for taking steps to eliminate conflicts of interest when employees, including spouses and third-degree relatives, are reporting to each other in the same organization. Managers and human resources recruitment officials who are in a position to make decisions in recruitment processes must implement measures to resolve conflicts of interest in the event that they are associated with a candidate who has applied for a job, including spouses and third-degree relatives.

4. DESIGNATING VIOLATION and NOTIFICATION

4.1. Designating Violation

Our stakeholders are welcome to ask the 4 questions below regarding any issue that they have any concerns about compliance with the DIAS Corporate Group Ethical Principles Policy while conducting their business.

Is it legal for me to do this?

Does this work comply with the DIAS Corporate Group Ethical Principles Policy?

Can I disclose my actions to other stakeholders?

How comfortable and secure would I feel if this was reported in the press?

If the answer to any of these questions is “No”, the work should not be performed. If all 4 questions are answered “Yes”, the business is regarded as ethical and can be performed. If you are not sure about these questions, you can ask the Ethics Committee of DIAS Corporate Group.

4.2. Notifying Violation

Without limitation, the following items are deemed to be in violation of the Dias Ethical Principles Policy:

All employees of DIAS Corporate Group regardless of their department, title and authority, consultants, customers, suppliers, all other third parties who have a business relationship with our group, and all those who are affected by the activities of our group can report to the Ethics Line in the event that they observe or suspect non-compliance with the principles, rules and responsibilities set out in this document. All stakeholders are responsible for not remaining voiceless when they witness a violation or have a concern regarding the DIAS Corporate Group Ethical Principles Policy. In order for stakeholders to report violations in confidence and not to be subjected to retaliation due to their reports, their identity information is held confidential by the DIAS Corporate Group Ethics Committee. Retaliation against an employee who witnesses a violation and raises a concern will not be tolerated. DIAS Corporate Group will take disciplinary action against employees who retaliate against those who report to the Ethics Hotline. Reports must clearly and in detail describe what the issue is, how, where and when it happened, and who was involved. In the event that there is concrete information or documents to support the allegation in the reports made, they should be shared with the report.

Ethical violation notifications can be sent to etik@diasteknoloji.com e-mail address. Stakeholders can notify the DIAS Corporate Group Ethics Committee through one of the notification channels they prefer. The Board is obliged to take all notifications seriously.

4.3. Investigation of Violations

The results of the study are transferred to the DIAS Corporate Group Ethics Committee for decision-making and evaluation of the violation after the necessary controls and examinations are carried out when any ethical violation of our stakeholders is detected.

In case of any violation of this Ethical Principles Policy or inappropriate behavior towards our stakeholders, DIAS Corporate Group may take administrative and criminal action or report to judicial authorities in accordance with the laws of the Republic of Turkey and DIAS Corporate Group Disciplinary Regulation after the investigations to be carried out by the DIAS Corporate Group Disciplinary Board.