ANTI-CORRUPTION POLICY

Deniz Gayrimenkul Yatırım Ortaklığı A.Ş. (“Deniz GYO”) is determined to comply with national and international legal regulations, ethical and professional principles to prevent bribery and corruption. It aims to provide the highest standards in its services and activities in line with the principles of honesty, transparency, accountability and objectivity.

Deniz GYO has defined the main principles of anti-corruption policy, which covers its main tasks and purposes related to anti-corruption, process stakeholders, the duties, authorities and responsibilities of the stakeholders, as well as the relations with third parties including individuals, legal entities, official institutions and representatives. Within this scope, it has established “Deniz GYO Anti- Corruption Policy” as per the relevant Turkish laws, methodologies, principles and best practices.

Through this policy, it is ensured that a general methodology is established regarding anti-corruption. All members of staff shall provide service with the awareness of anti-corruption and comply with the laws related to anti-corruption, this Policy and ethical principles.

Within the framework of Anti-Corruption Policy, Deniz GYO has made system related developments for all members of staff to confirm that they have read and understood the provisions of the Policy and to make necessary reporting in this scope.

In addition to the compliance of members of staff with other compliance procedures and ethical rules, the fulfilment of anti-corruption tasks continuously and faultlessly by the stuff is taken into consideration for the performance assessments. Deniz GYO establishes necessary control mechanisms, creates procedures and takes actions regarding the results of the controls to be able to detect, assess and reduce corruption risks efficiently. In this scope, Deniz GYO defines important functions, operation types, business processes and positions regarding anti-corruption, takes measures to prevent conflicts of interest, and defines procedures related to gift and hospitality expenditures and all other areas that may be subject matter of corruption.

In case of violation of Anti-Corruption Policy, disciplinary penalties/ judicial enforcements that may cause the termination of labour contract as per the related Turkish Laws and practices of the company can be applied.

Within the scope of Anti-Corruption Policy, in addition to the stuff, suppliers, contractors, customers and related third parties must fully comply with these principles and other related regulations.

The relevant provisions are included in the agreements/contracts/protocols, etc. concluded with counterparties to ensure this compliance.

Deniz GYO endeavours the required effort to decrease the risks of business relations with counterparties who are involved in anti- corruption activities or who may be involved in these activities.

Within the scope of prevention of corruption and bribery, in the light of reliability, accuracy, transparency and accountability principles, Deniz GYO aims to prevent the misuse and abuse of authorities, ensure the use of the sources as per law.

Within the scope of Anti-Corruption Policy, Deniz GYO has adopted the following as principle:

  • to comply with laws and regulations, universal law rules, and ethical principles,
  • to develop anti-corruption culture among its members of staff, customer and non-customer real persons/legal entities through briefings and trainings,
  • to make controls related to the implementation of the policy and procedures,
  • to develop measures and take necessary precautions to detect and limit corruption cases.

With the purpose of preventing corruption and bribery, parties concluding contracts with Deniz GYO hereby accept and undertake to comply with the below stated “Anti-Corruption Rules” and not to carry out the below stated actions and/or similar actions directly or indirectly, personally or through third parties.

Anti-Corruption Rules

  • Bribing or intermediating bribery; in other words, gaining any financial or other profit/advantage or promising on this accord in order to encourage a person to violate legislations and international regulations and/or benefiting the briber by using their own official post.
  • Making corrupt payments; in other words, by taking into account the status of company managers, transferring them illegal money, securities or other properties for them to behave/not behave in favour of the briber or presenting managers with said properties or providing managers with property rights.
  • Bribing public servants; in other words, offering any financial or other profit/advantage or promising them on this accord in order to get competitive or other advantages for Deniz GYO or to get/continue a deal by affecting the fulfilment of official duties of a public servant.
  • On behalf of themselves or third parties, Parties cannot conduct the below acts in relation of money, jewellery, other securities or property rights;
    • They cannot gain profit or abuse their duty to offer this profit to a party illegally, cannot intermediate any misconduct.
    • They cannot offer, give, promise, ask for, accept bribe and cannot abuse any authority owned directly or indirectly as per the position. They cannot carry out activities by illegal use of titles.
    • They cannot carry out activities stated above in the name or on behalf of Deniz GYO.